CARB has provided a proposed schedule for rulemaking and initial reporting under SB 253 and SB 261

At its Public Workshop held on August 21, 2025, CARB provided a proposed schedule for rulemaking and initial reporting under SB 253 and SB 261.

As a reminder, starting in 2026, business entities organized under U.S. law, doing business in California, and with annual revenues over $500M are required by SB 261 to make biennial disclosures regarding climate-related financial risk, and those with annual revenues over $1B are required by SB 253 to make annual disclosures of their green-house gas emissions.

As of the August 21 Workshop, some of the key dates being proposed by CARB are as follows:

• August 21 to September 11, 2025:  Public comment period on the CARB concepts presented at the Workshop
• End of September 2025:  CARB to post reporting templates for public feedback regarding Scope 1 and 2 emissions under SB 253
• October 14, 2025:  CARB notice of proposed rulemaking 
• October 17 to November 30, 2025:  Public comment period on the proposed rules
• December 11-12, 2025:  Board consideration of the proposed rulemaking
• December 1, 2025 to July 1, 2026:  Remains the timeframe for CARB to open a public docket for covered entities to post the public link to their initial SB 261 reports
• January 1, 2026:  Remains the statutory deadline for covered entities to post their initial SB 261 reports to their websites
• June 30, 2026:  Submission of SB 253 Scope 1 and 2 reporting

More information on the August 21 Public Workshop, and submitting public comments on the CARB concepts presented at that Workshop, can be found here.