CARB Posts Modified Regulations To Implement SB 261 and SB 253

On July 27, 2026, CARB posted modified regulations to implement SB 261 and SB 253. The prior version of these regulations was approved by CARB in February 2026, but their submission to the Office of Administrative Law for final review and approval was withdrawn to allow CARB to make changes and clarifications to the regulations. 

As a reminder, starting in 2026, business entities organized under U.S. law, doing business in California, and with annual revenues over $500M may be 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 modified regulations would, among other things:

• Extend the 2026 deadline to report Scope 1 and Scope 2 GHG emissions pursuant to SB 253 by three months, from August 10 to November 10, 2026.
• Clarify that, for only the report due on November 10, 2026, a reporting entity may submit either (1) Scope 1 and 2 emissions based on the information the reporting entity already possessed or was collecting on or before December 5, 2024, or (2) a statement on company letterhead indicating that the reporting entity did not possess and was not collecting Scope 1 and 2 emissions information on or before December 5, 2024.
• Clarifications to the definitions of “Doing business in California,” “Revenue,” and “Subsidiary.”

The modified regulations are subject to a fifteen-day public comment period, with public comments due by August 11, 2026.

More information on this rulemaking and the modified regulations can be found here.