CARB's SB 253 Initial Climate Disclosure Regulation Approved by California OAL
California's Office of Administrative Law approved CARB's initial SB 253 regulation on October 12, 2026, putting the state's climate disclosure and corporate greenhouse gas reporting regime into effect for in-scope businesses.
On October 12, 2026, the California Office of Administrative Law approved the California Air Resources Board's Initial Regulation implementing SB 253, the statute that codifies California's climate-related financial risk disclosure and corporate greenhouse gas reporting program. This is the operative rule rather than a proposal, so the scoping, thresholds, phasing and recordkeeping terms set out in the approved regulation now anchor compliance planning for entities doing business in California.
Why sophisticated counsel and clients care: the regime reaches companies with California operations irrespective of place of incorporation, and the approved text will shape data collection, internal controls, assurance readiness and the treatment of climate risk in disclosure documents, financing covenants and transaction diligence. Federal and multi-state climate disclosure initiatives remain in flux, so counsel should not assume this state rule is the last word or that it displaces other reporting obligations.
Next step to watch: the effective date and first compliance deadlines under the approved Initial Regulation, any subsequent CARB guidance or enforcement posture, and how overlapping federal developments may affect the state regime. Because the available alert excerpt does not reproduce the rule's operative provisions, teams should work from the approved text itself before advising on scope.