Key Takeaways
- • The California Office of Administrative Law approved CARB's initial regulation implementing aspects of California's corporate climate disclosure laws, effective October 12, 2026.
- • The regulation establishes an initial fee framework and sets November 10, 2026 as the first reporting deadline under SB 253, California's corporate greenhouse gas emissions disclosure law.
- • CARB has launched a voluntary online submission platform for Scope 1 and Scope 2 emissions reports, with email submission also accepted.
- • SB 253 generally applies to U.S.-based companies with more than $1 billion in annual revenue that do business in California; Scope 3 reporting is scheduled to begin in 2027.
- • Potentially covered companies should confirm applicability, finalize Scope 1 and Scope 2 data and choose a submission method, as the underlying deadlines remain mandatory despite the platform being voluntary.
Summary
The California Air Resources Board (CARB) announced that the California Office of Administrative Law has approved its initial regulation implementing aspects of the state's corporate climate disclosure laws. The regulation, effective October 12, 2026, was originally adopted by CARB in February. It establishes an initial fee framework and formalizes November 10, 2026, as the first reporting deadline under SB 253, California's corporate greenhouse gas (GHG) emissions disclosure law.
To facilitate initial reporting, CARB has launched a voluntary online submission platform through which covered companies can provide contact information and submit Scope 1 and Scope 2 emissions reports. Companies may alternatively submit their information by email. In September, CARB published updated reporting guidance and issued reminder letters to potentially covered entities. SB 253 generally applies to U.S.-based companies with more than $1 billion in annual revenues that do business in California, with Scope 3 reporting requirements scheduled to begin in 2027.
According to the source, the approval marks another significant step toward implementation of the program, despite legal challenges to SB 253 and broader federal efforts to scale back mandatory GHG reporting. The source notes that while use of CARB's platform is voluntary, the underlying reporting and compliance deadlines are not. It advises potentially covered companies to confirm their applicability assessments, finalize Scope 1 and Scope 2 emissions data and determine their preferred submission method ahead of the deadline, which is less than a month away.
The source also highlights the increasingly divergent federal and state approaches to corporate climate disclosure, arguing that maintaining emissions reporting capabilities is important even as federal requirements are increasingly eliminated. The item was published by Akin Gump, a law firm that has written extensively on SB 253 compliance matters.
To facilitate initial reporting, CARB has launched a voluntary online submission platform through which covered companies can provide contact information and submit Scope 1 and Scope 2 emissions reports. Companies may alternatively submit their information by email. In September, CARB published updated reporting guidance and issued reminder letters to potentially covered entities. SB 253 generally applies to U.S.-based companies with more than $1 billion in annual revenues that do business in California, with Scope 3 reporting requirements scheduled to begin in 2027.
According to the source, the approval marks another significant step toward implementation of the program, despite legal challenges to SB 253 and broader federal efforts to scale back mandatory GHG reporting. The source notes that while use of CARB's platform is voluntary, the underlying reporting and compliance deadlines are not. It advises potentially covered companies to confirm their applicability assessments, finalize Scope 1 and Scope 2 emissions data and determine their preferred submission method ahead of the deadline, which is less than a month away.
The source also highlights the increasingly divergent federal and state approaches to corporate climate disclosure, arguing that maintaining emissions reporting capabilities is important even as federal requirements are increasingly eliminated. The item was published by Akin Gump, a law firm that has written extensively on SB 253 compliance matters.
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