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California SB 253: Climate Corporate Data Accountability Act · 2026-initial-regulation-as-amended-sb219
Disclosure SB253-REPORTING-TIMELINE

Reporting timeline and filing status

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.

Dr Ross Kurinko, Sustainability Reporting Trainer
Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by CARB
To prepare this disclosure
Disclosure focus

This disclosure is about when an organisation must report and whether it has filed on time. In practical terms, it asks for a clear account of the reporting period covered, the status of the filing, and any relevant timing milestones so readers can see whether the organisation has met the required deadline or is still in progress.

The practical focus is on the organisation’s reporting coverage and readiness, not just a single site or a headline figure. The explanation should make clear whether the filing relates to the organisation as a whole and how far the reporting has been completed across the relevant operations included in the submission.

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.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Annual filing flag Whether this reporting obligation is set to recur every year. Policy note, reporting calendar, or statutory tracking schedule showing the recurring filing cycle. Sustainability reporting
First reporting year The first financial year or reporting year covered by this obligation. Board-approved reporting timetable, legal tracker, or finance calendar showing the initial year in scope. Finance
Initial emissions deadline The date by which the first greenhouse gas report for direct and purchased-energy emissions must be filed. Regulatory calendar, compliance tracker, or filing plan with the first due date recorded and approved. Sustainability reporting
First-year good faith flag Whether the first submission is being made on a good-faith basis. Internal filing memo, legal sign-off, or disclosure note confirming the first-year basis used. Legal
Carbon report lag The number of days allowed between the direct-and-energy filing and the later value-chain emissions filing. Compliance timetable or statutory deadline tracker showing the gap in days between the two submissions. Sustainability reporting
Value-chain start year The first reporting year from which value-chain emissions reporting begins. Regulatory interpretation note, reporting roadmap, or legal tracker showing the start year for this requirement. Sustainability reporting
Filing progress status The current state of the submission, such as planned, in progress, filed, or not yet started. Filing tracker, workflow status, or submission log showing the latest approved status. Sustainability reporting
+ Show SB253-REPORTING-TIMELINE sub-elements (LRA working checklist)

How to prepare it

1Confirm whether this is an annual filing for the organisation, then pin down the first reporting year or fiscal period that applies so the timeline is anchored to the right cycle.
2Set the first date for Scope 1 and Scope 2 disclosure, and record the current submission status so you can see whether the filing is planned, in progress, or complete.
3Check whether the first year allows a good-faith initial submission, and keep evidence showing how that judgement was reached.
4Work out when Scope 3 information becomes due after the Scope 1 and Scope 2 filing, and note the number of days used to calculate that follow-on deadline.
5Identify the year when Scope 3 reporting begins, then gather the supporting records for the figures or narrative that will be reported from that point onward.
6Keep a clear audit trail for any exclusions, timing changes, or restatements, and compare the final timeline against the official source before submission.
Request the data

Request the filing timeline and status details

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

What filing dates, status, and timing milestones should we use for the company’s climate reporting pack?

Use your organisation’s own filing and governance terms first, then map them to the reporting timeline items below. Keep the ask in the language your team already uses for board papers, statutory filings, and sustainability reporting, and check the source material before sign-off.

Weak request

Can you confirm the disclosure items for the reporting timeline and filing status?

Why it fails: It uses framework language instead of the team’s own filing terms, and it does not specify the period, entity boundary, source record, or the exact timing and status fields needed to complete the pack.

Better request

Please send the filing calendar details for [entity / group] for [reporting period]: whether this is an annual cycle, the first reporting year, the planned date for the first Scope 1 and 2 filing, whether the first-year filing was made on a good-faith basis, the number of days allowed before the Scope 3 filing, the year Scope 3 starts, and the current filing status. Include the source record and owner.

Formal email template
Subject: Request for filing timeline and status details for [reporting period]

Hi [name],

Could you please share the filing timeline and current status for [entity / group] for [reporting period]?

Please include:
- whether this is an annual filing cycle
- the first reporting year or cycle we should use
- the planned date for the first Scope 1 and Scope 2 filing
- whether the first-year submission was made on a good-faith basis
- the timing gap used for the Scope 3 filing after the Scope 1 and 2 filing
- the year when Scope 3 reporting starts
- the current submission status

Please also attach or link the source record you used, and note the owner / approver.

A possible LRA training template only — please adapt this to your organisation’s own terms and check the source material before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — could you send the filing timeline and status for [entity / group] for [reporting period]? Please include the annual cycle flag, first reporting year, first Scope 1 and 2 filing date, first-year good-faith flag, Scope 3 timing gap, Scope 3 start year, and current status. Please share the source record too. Adapt to your team’s own terms and check the source material before sign-off.
Industry examples
Manufacturing

Context. A group sustainability team needs the filing calendar from the company secretariat before drafting the board pack.

Adapted request. Please share the filing calendar for [group] for [reporting period], including whether the cycle is annual, the first reporting year, the first Scope 1 and 2 filing date, the first-year good-faith flag, the days allowed before the Scope 3 filing, the Scope 3 start year, and the current filing status. Please attach the board paper or tracker extract used.

Example response. Source: statutory filing tracker; Period: FY2025; Boundary: consolidated group; Annual cycle: Yes; First reporting year: FY2025; First Scope 1 and 2 filing date: 2026-06-30; First-year good-faith flag: Yes; Scope 3 gap: 90 days; Scope 3 start year: FY2026; Status: Draft approved for submission.

Retail

Context. A retail business with a central compliance calendar needs the timing details from legal before the disclosure is finalised.

Adapted request. Could you confirm the filing dates and status for [entity] in [reporting period]? Please include the annual filing flag, first reporting year, first Scope 1 and 2 deadline, whether the first year was handled on a good-faith basis, the delay used for the Scope 3 filing after the first filing, the year Scope 3 begins, and the current submission status. Please include the calendar entry or approval note.

Example response. Source: compliance calendar; Period: FY2024; Boundary: legal entity plus consolidated reporting group; Annual cycle: Yes; First reporting year: FY2024; First Scope 1 and 2 deadline: 2025-05-31; First-year good-faith flag: No; Scope 3 gap: 120 days; Scope 3 start year: FY2025; Status: Submitted.

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

This draft should explain which reporting year is being covered, how the organisation has defined the relevant fiscal period, whether the filing is treated as the first submission or a later one, and which emissions sources are included at each stage.

Context note

The figures should be read as a staged reporting journey: the organisation first discloses direct emissions and purchased-energy emissions, then adds wider value-chain emissions in the later phase, so the numbers reflect a phased build-up rather than a single all-at-once filing.

Fluctuation statement

If the reported position changes from one period to the next, the narrative can point to the move from the first filing year to later years, the shift from the initial deadline to the broader reporting stage, or a change in submission status as the reason for the difference.

Content index entry
SB253-REPORTING-TIMELINE Reporting timeline and filing status — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for SB253-REPORTING-TIMELINE — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
Go deeper · SB253-REPORTING-TIMELINE
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.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We have documented whether this filing cycle is one we must complete each year, and we have tied that decision to the relevant filing year.An assurer may ask whether the annual-cycle flag was set on the basis of the correct rule set and whether the team applied it consistently across reporting years.['Internal reporting calendar or compliance tracker showing the annual filing decision', 'A dated memo or control note explaining why the filing cycle was marked as required or not required', 'Review sign-off showing the decision was checked before publication']
We recorded the first year in which this disclosure applies, using the reporting year we prepared the figures for rather than the year of publication.An assurer may probe whether the first applicable year was identified correctly and whether the team used the right reporting period when populating the field.['Source schedule showing the first applicable reporting year', 'Working papers linking the disclosed year to the underlying fiscal period', 'Approval record confirming the year selection was reviewed']
For the first filing, we prepared the figures from the prior accounting period and kept that period clearly identified in the support pack.An assurer may test whether the disclosed numbers were actually drawn from the preceding fiscal period and whether any later-period data was mixed in.['Trial balance, ledger extract, or other period-end source data for the prior fiscal year', 'Reconciliation showing the disclosed figures trace back to that period', 'Evidence that the period boundary was checked before submission']
We noted the date by which the first direct emissions and purchased-energy disclosure had to be filed, and we used the date set by the regulator for that year.An assurer may ask whether the deadline recorded in the file matches the applicable year and whether the team relied on the correct external date.['Regulatory timetable or internal compliance calendar showing the deadline used', 'Submission plan or project timeline aligned to that date', 'Evidence of review confirming the deadline was entered correctly']
Where we marked the first-year submission as prepared in good faith, we kept evidence that the team took reasonable compliance steps during the build process.An assurer may probe whether the good-faith flag is supported by actual actions rather than a generic assertion, and whether those actions were taken in the first year.['Project logs, meeting notes, or task tracker showing compliance actions taken', 'Evidence of data collection, review, and escalation steps completed during the first year', 'Management or control sign-off supporting the good-faith designation']
We recorded the later-stage emissions filing as due after the earlier filing for the same reporting period, and we kept the timing calculation on file.An assurer may test whether the later filing date was calculated from the correct earlier submission date and whether the interval was applied properly.['Calendar calculation or timeline showing the gap between the two filings', 'Copies of the earlier filing date and the later due date used in planning', 'Review evidence confirming the timing was checked before publication']

Evidence pack to prepare

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
The request goes to a team that does not hold the filing calendar or status record, so the answer comes back from the wrong part of the business.
Framework language only
People ask for the data using reporting-framework terms instead of the company’s own labels, and the owner cannot map the request to their working records.
No boundary set
The team never agrees which legal entity, business unit, or reporting population is in scope, so different people pull different sets of records.
+ Show 6 more

Where judgement is often needed

Set the first reporting year after a deal closes
If an acquisition or disposal changes the group during the year, choose one cut-off date for the reporting population, explain which entities were included or removed, and keep the same basis for the first year and the filing status you report.
Decide how to handle businesses with mixed-country operations
Where local records, calendars or entity definitions differ across countries, use one group-wide approach for the timeline fields, explain any country-specific exceptions, and show how those differences affect the year and deadline you state.
Draw the line for entities near the reporting boundary
For joint ventures, minority holdings, newly formed entities or dormant operations, state the inclusion rule you applied, explain any exclusions, and make clear whether the choice changes the first year or the submission status.
+ Show 5 more
Examples

Illustrative examples

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

Illustrative (synthetic) example — manufacturing

We treat this as an annual filing cycle, with our first year of reporting set to FY2026. Our initial Scope 1 and Scope 2 filing would be due by 30 June 2027, and that first submission may be made on a good-faith basis. - Scope 3 comes later, after the first Scope 1/2 filing has been made; for us, that starts in FY2027. - Status: we would mark the first filing as submitted, with Scope 3 not yet due in that opening year.

Illustrative only; shows the timing sequence for the first year, the later start for value-chain emissions, and the possibility of a good-faith opening submission.

Illustrative (synthetic) example — financial services

We report on an annual basis, with our first reporting period set to FY2027. Our first Scope 1 and Scope 2 return would be due by 30 June 2028, and we would use the good-faith option for that opening submission. - The wider value-chain disclosure follows after the first direct-emissions and purchased-electricity filing; in our case, that begins in FY2028. - Status: the first return would be filed, while the later value-chain piece would remain pending until its start year.

Illustrative only; shows a different sector, a later first year, the first deadline, the good-faith opening filing, and the later start for value-chain reporting.

Company reportsReal published reports
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How companies report SB253-REPORTING-TIMELINE in practice

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

Host Hotels & Resorts, Inc.
Real Estate · United States · 2025
Open report →
Host Hotels & Resorts, Inc.'s 2025 Corporate Responsibility Report provides detailed data on Scope 1 greenhouse gas emissions, reporting 92,608 MT CO2e for 2024 on page 54 and historical emissions data from 2020 to 2024 on page 53. The report also references Scope 2 and Scope 3 emissions, with some figures and context found on pages 18, 54, and 58, though the exact reporting timeline for Scope 1 and 2 deadlines remains unclear (p.4). Notably, the report does not include explicit information on the first reporting year under SB253, good faith first-year submission, or Scope 3 reporting deadlines and start year.
Sands China Ltd.
Hotels, Restaurants, Leisure, Tourism Services · Macao · 2025
Open report →
Sands China Ltd.’s 2025 ESG Report provides verified data on Scope 1 and 2 greenhouse gas (GHG) emissions, energy, water, and waste, with verification conducted by LRQA to a reasonable level (p.26). The report includes a detailed GHG emissions summary from 2018 to 2025, showing Scope 1 emissions figures and a breakdown of Scope 3 emissions by category for 2025 (p.31). However, there is no evidence regarding the reporting timeline requirements such as annual reporting, first reporting year, or submission status.
Cargill
Food Production — Agricultural · United States · 2025
Open report →
Cargill's 2025 Impact Report provides partial coverage of the SB253 reporting timeline disclosure, with some context on Scope 1 and Scope 2 greenhouse gas (GHG) emissions and related reductions, including a 10% absolute operational GHG emissions reduction target by 2025 from a 2017 baseline (p.14) and a 23.2% improvement in Scope 1 and 2 GHG intensity in Norway in 2024 (p.58). The report also references Scope 3 emissions and due diligence efforts, though without a clear headline value or specific timeline for Scope 3 reporting (p.14, p.99). Notably, there is no clear disclosure of the first reporting year, the first Scope 1 and 2 deadline, submission status, or good faith first-year submission, and the timeline for annual reporting is not found (p.109; no page).
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Check your understanding

Scenarios to work through

A preparer has confirmed the organisation will report every year, but the first filing cycle is still being mapped because the finance team uses a non-calendar fiscal year. The draft pack also shows the first greenhouse-gas filing date has been set, but no one has yet agreed whether the first-year pack will be treated as a good-faith first submission.

QHow should the preparer decide the first reporting year, the first Scope 1 and 2 filing date, and whether the first-year submission is being treated as a good-faith first filing?
Reveal model answer →

A sustainability lead is preparing the next disclosure pack and notices that Scope 1 and 2 data will be filed first, while Scope 3 work is still being gathered from suppliers. The team is unsure whether the Scope 3 deadline should be shown as a fixed number of days after the earlier filing or as a separate date.

QWhat is the right way to set the Scope 3 timing field when Scope 3 follows the earlier emissions filing?
Reveal model answer →

A reporting manager is reviewing a draft and sees the status field marked as “in progress” even though the first filing has already been sent to the regulator. The pack also includes the first reporting year and the first emissions deadline, both of which match the submission that was sent.

QWhat filing status should be shown once the first submission has actually been sent?
Reveal model answer →

An internal reviewer finds that the organisation plans to report annually, but the draft template leaves the annual reporting field blank because the team assumed it was obvious from the narrative. The same draft also lists a first-year date and a Scope 3 start year, but there is no clear yes/no entry for annual reporting.

QShould the annual reporting field be completed even if the narrative already explains the cycle?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

California
SB253-REPORTING-TIMELINE
within California SB 253: Climate Corporate Data Accountability Act
Open official source →
Primary
Related & explore
Go deeper · SB253-REPORTING-TIMELINE
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.

FAQ

Questions this page answers

For SB253-REPORTING-TIMELINE, what data points do I need to gather before I start the disclosure draft?+
How do I use the step-by-step 'how to prepare' section for SB253-REPORTING-TIMELINE in practice?+
What should I include in the evidence pack for SB253-REPORTING-TIMELINE assurance readiness?+
What are the six assurance claims I need to verify for SB253-REPORTING-TIMELINE?+
What are the common reporting gaps or mistakes on the SB253-REPORTING-TIMELINE page, and how do I avoid them?+
How do I use the Prep & Assurance workbook for SB253-REPORTING-TIMELINE?+
What is the printable Library Card PDF for SB253-REPORTING-TIMELINE for?+
Can I use the synthetic illustrative example disclosures on the SB253-REPORTING-TIMELINE page as a template for my own draft?+
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More questions this page can help with
SB253-REPORTING-TIMELINE workbook download: what should I fill in first?SB253-REPORTING-TIMELINE evidence pack checklist for assurance readinessSB253-REPORTING-TIMELINE common mistakes before filingSB253-REPORTING-TIMELINE draft narrative starters and content index lineSB253-REPORTING-TIMELINE synthetic example disclosure tableSB253-REPORTING-TIMELINE annual filing flag and first reporting year explained for practitionersSB253-REPORTING-TIMELINE initial emissions deadline and carbon report lag data collectionSB253-REPORTING-TIMELINE value-chain start year and filing progress statusSB253-REPORTING-TIMELINE assurance claims claim risk evidenceSB253-REPORTING-TIMELINE from company reports examplesSB253-REPORTING-TIMELINE ESRS E1 data reuseSB253-REPORTING-TIMELINE how to prepare disclosure step by step
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