CARB Provides Updated Guidance on California Climate-Reporting Laws (SB 261 & SB 253)

On November 17, 2025, CARB posted updated FAQs on SB 261 and SB 253, and an updated Checklist for SB 261. On November 18, 2025, CARB also held a Public Workshop where these and other updates were discussed.

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 their climate-related financial risk, and those with annual revenues over $1B will be required by SB 253 to make annual disclosures of their greenhouse gas emissions.

The updates CARB provided on November 17 and 18 included the following regarding SB 253 reporting:

• The proposed initial reporting deadline for SB 253 has been extended to August 10, 2026.
• For the 2026 reporting cycle, reporting entities that were not collecting data or were not planning to collect data when CARB’s Enforcement Notice was issued on December 5, 2024, do not have to submit Scope 1 and 2 emissions data under SB 253, and may instead document this in a letter to CARB on company letterhead that is uploaded to CARB’s public docket.
• For the 2026 reporting cycle, Scope 1 and 2 emissions reporting does not need to receive assurance from an independent third-party assurance provider.

CARB’s November 17 updated FAQs and Checklist can be found here, and materials from the November 18 Public Workshop can be found here.