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California SB 253: Climate Corporate Data Accountability Act · 2026-initial-regulation-as-amended-sb219

Disclosure SB253-SCOPE-3

Scope 3 greenhouse gas emissions

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official CARB source.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by CARB

To prepare this disclosure

6datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to report its Scope 3 greenhouse gas emissions, meaning the emissions linked to its wider value chain rather than only emissions from its own facilities or energy use. In practice, the focus is on capturing the organisation’s indirect emissions profile in a way that reflects the activities it relies on, such as purchased goods and services, transport, use of sold products, and other upstream and downstream sources where relevant.

The practical emphasis is usually on coverage across the organisation’s operations and value chain, not just a few flagship sites or the easiest-to-measure activities. Organisations should think about whether their reporting approach is broad enough to reflect the full business footprint, while also being clear about any gaps, estimates, or areas where data quality is still developing.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official CARB source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Have you settled which upstream and downstream activity groups you will include in the total, and which ones you will leave out? Will the figures come from one defined reporting window, and is that period the same one used across the rest of your emissions work? Can each category figure be traced back to a source record or dataset, rather than only to a summary total? For each category, have you decided whether the input comes from direct records, a secondary dataset, a proxy, or an industry-average source? Have you fixed the method you will use to turn activity data into emissions for each category, so the approach is consistent and explainable?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Included Scope 3 categories List which indirect emissions categories are counted in the reported Scope 3 figure, using the organisation’s chosen category set for the period. GHG inventory boundary note, category list in the emissions workbook, reporting pack sign-off. Sustainability reporting / ESG data owner

Category emissions split Capture the emissions amount for each included Scope 3 category, with each category mapped to its own figure for the same reporting period. Category-level emissions schedule, calculation workbook, source activity data and emission factor files. Carbon accounting / sustainability analytics

Data source mix Record which parts of the Scope 3 calculation use direct records, supplier-provided inputs, proxy estimates, or sector averages. Methodology note, source log, supplier data extracts, estimation workbook. Carbon accounting / data methodology lead

Estimation approach Describe the calculation approach used to turn activity data into Scope 3 emissions, including the main estimation logic applied. Calculation methodology, model notes, emission factor library, assumptions register. Carbon accounting / methodology owner

Reporting year window State the exact reporting period used for the Scope 3 figure, including the start and end dates covered by the data. Annual reporting timetable, consolidation calendar, period control sheet. Financial reporting / ESG reporting controller

Scope 3 total emissions Provide the single total amount of Scope 3 emissions for the reporting period, expressed in tonnes of carbon dioxide equivalent. Final consolidated emissions statement, signed reporting pack, calculation summary. Carbon accounting / ESG reporting owner

＋ Show SB253-SCOPE-3 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: confirm which indirect emissions sources you are covering for the period, and list the categories you will include in the submission.

2For each included category, decide what counts as in-scope activity and gather the supporting records that show the source data used to build the calculation.

3Choose and record the calculation approach for each category, including whether you relied on direct data, supplier information, estimates, or sector averages.

4Compile the figures by category and then roll them up to the overall total for the reporting year, keeping the category breakdown and the total consistent with each other.

5Note any exclusions, substitutions, or changes in method, and explain why they were made so the final submission can be traced back to the underlying evidence.

6Check the completed disclosure against the official source before filing, making sure the period, category list, methods, evidence trail, breakdown, and total all align.

Request the data

Request the Scope 3 emissions data

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What is the organisation’s total indirect emissions figure for the reporting period, with the category split, source basis and calculation approach behind it?

Use your organisation’s own names for the teams, systems and emissions buckets first, then map them to the reporting categories for this request. Keep the ask in everyday operational language rather than framework wording, and check the official source before sign-off.

Weak request

Please provide the Scope 3 disclosure data for the reporting period, including category coverage, category emissions, data sources, estimation methods and total emissions.

Why it fails: It uses framework language that many operational teams do not use day to day, so the owner may not know which systems, buckets or files to pull. It also does not tell them how to present the split, what to include as evidence, or which internal labels to use.

Better request

Please send the indirect emissions figures for [reporting period], split by your internal emissions buckets, with the source used for each bucket, the calculation approach, and the total for the period. Include any buckets that are only partly covered or excluded, and return the file or system name used to build the numbers.

Formal email template

Subject: Request for indirect emissions data for [reporting period]

Hi [name/team],

I’m pulling together the sustainability reporting pack and need your help with the indirect emissions figures for [reporting period].

Please send:
- the total indirect emissions figure for the period;
- the breakdown by your internal emissions buckets / activity areas;
- which buckets are included in the total and which are not;
- the data sources used for each bucket (for example, actual records, supplier data, proxy or industry-average estimates);
- the calculation approach used;
- the reporting period covered;
- the file name, system, or model used to produce the numbers.

Please return the figures in a table and add a short note on any assumptions, gaps, or changes from the prior period.

If helpful, I can send a simple template. Please adapt this to your organisation’s own terms first, then map it to the reporting categories. Check the official source before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name/team] — could you send the indirect emissions figures for [reporting period], plus the split by your internal buckets, the data source for each one, and the method used to calculate them? Please include any exclusions, assumptions, and the file/system used. I can share a simple template if useful. Please adapt this to your organisation’s own terms first, then map it to the reporting categories. Check the official source before sign-off.

Industry examples

Retail

Context. A retailer tracks emissions across stores, warehouses, transport and supplier spend.

Adapted request. Please send the indirect emissions figures for [reporting period], split by your internal buckets such as inbound freight, outbound delivery, packaging, waste, business travel and purchased goods. For each bucket, include the source used, whether it is actual data or an estimate, and the method used to calculate emissions.

Example response. A table showing each bucket, the mapped reporting category, the data source type, the calculation method, and emissions in tCO2e, plus a note that supplier-specific data was available for some purchased goods lines and spend-based estimates were used for the rest.

Manufacturing

Context. A manufacturer collects data from procurement, logistics, travel and product teams.

Adapted request. Please send the indirect emissions figures for [reporting period], split by your internal activity areas such as raw materials, inbound freight, outbound logistics, waste, employee travel and product use assumptions. Include the source system for each area, the basis used where actual records are not available, and the total emissions for the period.

Example response. A spreadsheet with each activity area, the source system, whether the figure is based on primary records or a proxy, the calculation method, and emissions in tCO2e, plus a note that logistics data came from the transport management system and some supplier inputs were estimated using industry averages.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State which value-chain categories are included, what reporting period the figure covers, which calculation methods were used, and whether the inputs came from direct records, secondary records, proxy data, or sector averages.

Context note

Explain that the total reflects emissions across the included value-chain categories, while the category split shows where the main contributions sit and how much each part adds to the overall figure.

Fluctuation statement

If the total or category mix changes, point to shifts in the included categories, the underlying data sources, or the estimation approach, and note whether the reporting period itself also changed.

Content index entry

SB253-SCOPE-3 Scope 3 greenhouse gas emissions — [location / page] / [notes]

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Preparation tools & forms

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01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Go deeper · SB253-SCOPE-3

Learn to prepare this disclosure end-to-end

This guide covers one statutory requirement. The California Climate Regulation course walks SB 253 and SB 261 end to end — applicability, GHG inventories, climate-risk reporting and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We set out which parts of the wider value-chain inventory we included in the coverage figure, so readers can see the boundary we used.An assurer may test whether the boundary was chosen consistently, whether any relevant parts were left out without explanation, and whether the wording could mislead readers into thinking the figure is more complete than it is.Inventory boundary paper; category inclusion/exclusion list; methodology note explaining any omissions; management sign-off on the final boundary.

We broke the disclosed amount down by category, rather than only giving one combined figure, so the underlying components can be traced.An assurer may probe whether each category total is supported by source data, whether categories were grouped or split consistently, and whether the sum of the parts reconciles to the published total.Category-level calculation workbook; source extracts for each category; reconciliation from category totals to the published aggregate; review notes for any regrouping or mapping decisions.

For each part of the calculation, we recorded the type of input used, including direct records, third-party information, estimated inputs, and benchmark-based inputs where relevant.An assurer may challenge whether the input type was correctly classified, whether weaker inputs were used where better evidence was available, and whether the mix of inputs creates a material quality issue.Data source register; evidence of source classification for each line item; supplier or internal records; rationale for any estimated or benchmark-based inputs.

We documented the calculation approach we used for the disclosed amount, including the estimation steps and any conversion or allocation logic applied before publication.An assurer may test whether the method was applied consistently, whether the chosen approach fits the stated accounting basis, and whether the calculation logic contains errors or unsupported assumptions.Methodology memo; calculation model; emission factor or conversion factor file; assumption log; version-controlled spreadsheets or system outputs.

Where the reporting boundary changed because of a transaction or other structural event, we adjusted the disclosed amount using the same accounting approach throughout the period.An assurer may ask whether acquisitions, disposals, mergers, or similar events were identified completely, whether the treatment was consistent with the stated method, and whether the adjustment could distort comparability.Corporate transaction register; boundary-change assessment; supporting schedules showing pre- and post-change treatment; approval of the adjustment approach.

We stated the prior financial year covered by the data and checked that the publication timing aligned with the required sequence of disclosures.An assurer may verify that the period stated matches the underlying data set, that the timing is correct relative to the earlier public release, and that the reported year is not ambiguous.Reporting calendar; published dates for the earlier disclosure and the current one; period-end data extracts; final disclosure draft showing the stated year.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner asked

The team chases the sustainability lead for figures that sit with procurement, logistics, finance, or another operational owner, so the source data never comes from the people who actually hold it.

Framework terms used too early

People ask for the data in reporting-language terms instead of the business terms used day to day, and the request is misunderstood or routed to the wrong internal team.

Boundary left vague

No one pins down which parts of the business, subsidiaries, or activities are in the data set, so different teams collect different slices and the final numbers do not line up.

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Where judgement is often needed

Set the group boundary after a buy-in or sale

Decide whether to include emissions from businesses added or removed during the year, explain the cut-off date you used, and keep the same approach unless a change is clearly justified.

Handle mixed country definitions with one internal rule

Where local records use different business or activity definitions, map them to one group-wide method, note any exceptions, and explain how you translated the source data.

Decide how to treat activities near the edge of the value chain

For items that could sit inside or outside the reporting boundary, state the rule used to include or exclude them and describe any material judgement made.

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Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Manufacturing

: for the 2025 reporting year, we have set out the parts of our value-chain footprint that we included, the emissions attached to each part, and the methods and data types used to build the estimate. Our total Scope 3 figure is 1,240,000 tCO2e.

Illustrative only. Shows a concise first-person disclosure that names the included value-chain areas, gives category-level figures, and explains the main estimation approach and data inputs used for the year.

Illustrative Scope 3 breakdown for the 2025 reporting year (tCO2e)

Purchased goods and services420000

Capital goods90000

Fuel- and energy-related activities60000

Upstream transport and distribution110000

Waste generated in operations30000

Use of sold products530000

Illustrative (synthetic) example — Retail

: for the 2025 reporting year, we included the value-chain areas listed below and estimated them using a mix of primary records, supplier inputs, proxy data, and sector averages where needed. Our total Scope 3 figure is 385,000 tCO2e.

Illustrative only. Shows a second plausible reporter with a different mix of included areas and a smaller footprint, while still identifying the reporting year, the data sources used, and the estimation approach.

Illustrative Scope 3 breakdown for the 2025 reporting year (tCO2e)

Purchased goods and services150000

Upstream transport and distribution25000

Waste generated in operations10000

Business travel15000

Employee commuting5000

Downstream transport and distribution180000

Company reportsReal published reports

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How companies report SB253-SCOPE-3 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

C.H. Robinson

Air Freight Transportation and Logistics · United States · 2025

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C.H. Robinson’s 2025 Sustainability Report provides a total Scope 3 greenhouse gas emissions figure, reported as 17,811,002 metric tonnes CO2 equivalent on page 62. The report references Scope 1, 2, and 3 emissions and includes some discussion of emissions intensity targets and an emissions dashboard (pp. 17, 21), but it does not provide a breakdown of Scope 3 categories, data sources, or the reporting period. Additionally, the report lacks clear information on the methods used to estimate Scope 3 emissions.

Cargill

Food Production — Agricultural · United States · 2025

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Cargill's 2025 Impact Report includes coverage of Scope 3 emissions, specifically noting the footprint of agricultural commodities sourced from producers (p.19). The report also references Scope 3 emissions in the cocoa and chocolate supply chain and related farmer support initiatives (p.65). However, the report does not provide a detailed breakdown of Scope 3 categories, data sources, estimation methods, reporting period, or total Scope 3 emissions, leaving these aspects unclear or missing.

Bank of America

None · United States · 2025

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Bank of America's 2025 sustainability report provides some context on Scope 3 emissions, noting the organizational boundary for GHG emissions reporting and gases included in Scope 1, 2, and 3 calculations (p.18). The report includes data on financed emissions by sector and subsector boundaries for 2023 and 2024 (p.23), as well as information on carbon credit retirements affecting net Scope 1 and market-based Scope 2 emissions (p.20). However, the report lacks clear disclosures on Scope 3 categories included, category breakdowns, data sources, reporting periods, and estimation methods, with the total Scope 3 emissions figure remaining unclear (p.18).

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Check your understanding

Scenarios to work through

A preparer has a draft table for the year ended 31 December 2025. It shows a single total for value-chain emissions, but the working papers only cover purchased goods, transport, and business travel; no other categories have been assessed yet.

QShould the disclosure go out with only those three categories listed, or does the team need to confirm whether any other value-chain categories are included before sign-off?

Reveal model answer →

A company has calculated its value-chain emissions using supplier-specific activity data for some purchased materials, spend-based estimates for freight, and an industry-average factor for leased assets. The draft notes mention the methods, but not which source type was used for each category.

QIs it enough to say the figures were estimated, or does the preparer need to identify the source type used for the different parts of the calculation?

Reveal model answer →

A group reports its value-chain emissions for the 2025 financial year, but one business unit has used calendar-year supplier data and another has used a rolling 12-month estimate ending in March 2025. The consolidated total is ready, but the reporting note does not explain the period basis.

QCan the preparer present the total without clarifying the time period used for the underlying calculations?

Reveal model answer →

A preparer has a final value-chain total of 18,400 tCO2e for 2025. The category breakdown adds up correctly to that total: purchased goods 9,600 tCO2e, upstream transport 2,300 tCO2e, business travel 1,100 tCO2e, and other categories 5,400 tCO2e.

QIs the total enough on its own, or should the disclosure also show the split by category and the overall figure together?

Reveal model answer →

Framework references