On October 10, 2025, CARB released, and is seeking public comment on, its draft SB 253 reporting template for Scope 1 and 2 greenhouse gas (GHG) emissions. 

As a reminder, SB 253 requires business entities organized under U.S. law, doing business in California, and with annual revenues over $1B to (1) starting in 2026, annually disclose their Scope 1 and 2 GHG emissions for the prior fiscal year and (2) starting in 2027, annually disclose their Scope 3 GHG emissions for the prior fiscal year.

CARB’s draft reporting template for Scope 1 and 2 emissions will be optional for the 2026 reporting cycle.  It is intended to streamline reporting, particularly for those entities disclosing GHGs for the first time.

In an accompanying memo, CARB indicates that it is particularly interested in comments on the following aspects of the draft reporting template:

1. The proposal to disclose Scope 1 and 2 emissions by emission source, with fields for disclosure by types of GHGs (if data are available);
2. The proposal to allow organizational boundaries to be identified by the equity share, financial control, or operational control approaches, as opposed to requiring all reporting entities to use one approach; and
3. The proposed inclusion of a field to report emission reductions associated with direct contracts for renewable electricity and renewable gas, and whether other types of emission reduction initiatives or targets should be included in the template. 

Public comments should be posted to CARB’s public docket, or provided via email to [email protected], by October 27, 2025.  CARB’s draft reporting template, CARB’s accompanying memo, and further detail on submitting comments can be found on CARB’s website here.