Key Takeaways
- CARB has launched a voluntary 2026 Report Intake Platform and published new SB 253 reporting guidance to help in-scope companies prepare for California’s first corporate greenhouse gas emissions disclosure deadline this November.
- U.S. companies “doing business” in California with over $1 billion in annual revenue must submit Scope 1 and Scope 2 emissions reports by November 10, 2026, with Scope 3 reporting beginning in 2027.
- Under CARB’s enforcement discretion policy, first-year reporters may submit emissions data based on information they were already collecting as of December 2024, and companies that were not collecting data at that time should submit a statement of non-reporting instead.
On September 1, the California Air Resources Board (CARB) released new resources to help companies prepare for the first reporting deadline under California’s corporate greenhouse gas emissions disclosure regime.
Who Must Report Under California SB 253?
Under Senate Bill 253, U.S.-based companies doing business in California with more than $1 billion in annual revenue will be required to disclose their greenhouse gas emissions. For the first reporting year, covered companies must report their Scope 1 and Scope 2 emissions by November 10, 2026. Scope 3 reporting is scheduled to begin in 2027.
To assist companies with the first reporting cycle, CARB has launched a voluntary 2026 Report Intake Platform. Companies can use the platform to provide CARB with contact information in advance of the deadline and, if they choose, submit their Scope 1 and Scope 2 emissions reports through the platform. Use of the platform is not mandatory, and companies may also submit their emissions reports and contact information to CARB by email.
CARB has also published a Guidance Document for SB 253 2026 Reporting Submittals and a video tutorial walking users through the voluntary intake platform.
Regulatory Status of CARB’s SB 253 Initial Regulation
The reporting requirements are part of CARB’s implementation of SB 253 and its California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation (Initial Regulation). CARB approved the Initial Regulation on February 26, 2026, establishing the fee component of the program and the November 10 deadline for first-year reporting. The Initial Regulation remains subject to approval by the California Office of Administrative Law.
What Should Companies Do Before the November 2026 Deadline?
With the first reporting deadline now just over two months away, in-scope companies should be finalizing their Scope 1 and Scope 2 emissions data, and reviewing CARB’s newly released reporting guidance and submission options.
The Enforcement Discretion CARB Is Applying to First-Year Reporters
As a reminder, pursuant to the December 2024 Enforcement Notice and CARB’s Frequently Asked Questions document, CARB will allow reporting companies to submit Scope 1 and Scope 2 emissions for their prior fiscal year based on information they already have or were collecting when the December 2024 Notice was issued, whether or not the data received limited assurance. Only with respect to the first reporting cycle in 2026, entities that were not collecting data or were not planning to collect data at the time the Enforcement Notice was issued are not expected to submit Scope 1 and 2 reporting data. CARB requests that these companies submit a statement of non-reporting indicating that they were not collecting data and were not planning to collect data at the time the Enforcement Notice was issued.
If you have any questions about CARB’s SB 253 reporting requirements, the voluntary 2026 Report Intake Platform, or how the first-year enforcement discretion policy may affect your company’s GHG disclosure approach, please contact the author or your relationship partner at Bass, Berry & Sims.
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