Disclosure focus
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.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Annual filing flag
Sustainability reportingWhether this reporting obligation is set to recur every year.
Evidence Policy note, reporting calendar, or statutory tracking schedule showing the recurring filing cycle.
Watch for Annual and one-off filing cycles are mixed up, so the reporting calendar does not match the legal cadence.
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First reporting year
FinanceThe first financial year or reporting year covered by this obligation.
Evidence Board-approved reporting timetable, legal tracker, or finance calendar showing the initial year in scope.
Watch for The first in-scope year is misread as the current year, so the opening reporting period is wrong.
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Initial emissions deadline
Sustainability reportingThe date by which the first greenhouse gas report for direct and purchased-energy emissions must be filed.
Evidence Regulatory calendar, compliance tracker, or filing plan with the first due date recorded and approved.
Watch for The filing date is taken from the wrong reporting cycle, so the first direct-and-energy emissions deadline is off.
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First-year good faith flag
LegalWhether the first submission is being made on a good-faith basis.
Evidence Internal filing memo, legal sign-off, or disclosure note confirming the first-year basis used.
Watch for The first-year basis is not recorded correctly, so a good-faith submission is treated as a normal final filing.
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Scope 3 timing basis
Sustainability reportingUse the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
Evidence Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
Watch for The lag is counted from the wrong anchor date, so the later emissions filing deadline is mis-set.
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Value-chain start year
Sustainability reportingThe first reporting year from which value-chain emissions reporting begins.
Evidence Regulatory interpretation note, reporting roadmap, or legal tracker showing the start year for this requirement.
Watch for The start year is confused with the first direct-and-energy year, so value-chain reporting begins too early or too late.
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Filing progress status
Sustainability reportingThe current state of the submission, such as planned, in progress, filed, or not yet started.
Evidence Filing tracker, workflow status, or submission log showing the latest approved status.
Watch for The workflow status does not match the actual filing log, so a draft, submitted, or overdue return is labelled incorrectly.
Before you start
- Is this one of the years when you actually need to file, or is it outside the reporting cycle?
- Which financial year are you using as the basis for the first filing, and is that the same period your records are built on?
- Have you pinned down the first date by which the emissions figures must be submitted, and is that date traceable to a source document?
- For the first year, are you treating the submission as a good-faith estimate rather than a fully finalised set of numbers?
- Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
- Have you confirmed the year when Scope 3 reporting starts, and does your current status reflect that timing?
How to prepare it
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 for [entity] and [reporting period], with the confirmed legal deadlines, source references, actual submission status and assurance obtained. Record later emissions deadlines separately and identify the evidence owner. Do not assume a fixed interval between filings.
Formal email template
Please send the filing calendar for [entity] and [reporting period], with the confirmed legal deadlines, source references, actual submission status and assurance obtained. Record later emissions deadlines separately and identify the evidence owner. Do not assume a fixed interval between filings.
Short Teams / Slack version
Please send the filing calendar for [entity] and [reporting period], with the confirmed legal deadlines, source references, actual submission status and assurance obtained. Record later emissions deadlines separately and identify the evidence owner. Do not assume a fixed interval between filings.
Industry examples
Manufacturing
Context. A group sustainability team needs the filing calendar from the company secretariat before drafting the board pack.
Adapted request. Please send the filing calendar for [entity] and [reporting period], with the confirmed legal deadlines, source references, actual submission status and assurance obtained. Record later emissions deadlines separately and identify the evidence owner. Do not assume a fixed interval between filings.
Example response. Illustrative planning record: reporting period, legal deadline and source checked, planned submission date, actual submission status and assurance obtained. Keep the later emissions timetable separate; confirm it against current CARB guidance.
Retail
Context. A retail business with a central compliance calendar needs the timing details from legal before the disclosure is finalised.
Adapted request. Please send the filing calendar for [entity] and [reporting period], with the confirmed legal deadlines, source references, actual submission status and assurance obtained. Record later emissions deadlines separately and identify the evidence owner. Do not assume a fixed interval between filings.
Example response. Illustrative planning record: reporting period, legal deadline and source checked, planned submission date, actual submission status and assurance obtained. Keep the later emissions timetable separate; confirm it against current CARB guidance.
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
Download preparation tools for SB253-REPORTING-TIMELINE with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
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.
Risk 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.
Evidence to check ['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.
Risk 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.
Evidence to check ['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.
Risk 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.
Evidence to check ['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.
Risk 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.
Evidence to check ['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.
Risk 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.
Evidence to check ['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']
Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
Risk Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
Evidence to check Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe 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 onlyPeople 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 setThe team never agrees which legal entity, business unit, or reporting population is in scope, so different people pull different sets of records.
- Wrong time basisSomeone uses the wrong year, period end, or cut-off date, which means the timeline is built from the wrong reporting cycle.
- Mixed counting basisDates and durations are calculated from different reference points, so the deadline and start-year fields no longer line up with each other.
- Source labels lostThe original file names, system tags, or record titles are stripped away during collection, making it hard to trace where each timeline value came from.
- Populations mergedSeparate filing groups are combined into one extract even though they should stay distinct, which hides differences in status or timing.
- No evidence trailThe team captures the values but not the supporting metadata, so there is no clear record of who provided them, when, or from which source.
- No sign-off recordThe final set of dates and status flags is used without a visible review trail, so nobody can show who checked it before it was passed on.
Judgement needed
- Set the first reporting year after a deal closesIf 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 operationsWhere 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 boundaryFor 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.
- Choose one timing basis and stick to itIf internal reporting, statutory filing and operational close dates do not match, pick one basis for the timeline fields, describe why it was used, and disclose any gap between the date you used and the date other teams track.
- Explain when you used estimates instead of direct recordsIf the first-year submission or later timeline data relies on estimates, say which parts were estimated, why measured data was not available in time, and how you will replace or refine the estimate in later cycles.
- State how you treated rounding in dates and day countsIf you round a deadline, day interval or year label for presentation, disclose the rounding rule, keep the underlying calculation traceable, and ensure the rounded result still matches the filing sequence you describe.
- Aggregate sensitive timing data before sharing itIf detailed entity-level dates could expose personal or commercially sensitive information, combine them into a higher-level view, explain the aggregation method, and confirm that the summary still supports the filing status you report.
- Clarify whether the first-year submission was complete or partialIf the first filing was made with limited information, state whether it was a full or good-faith submission, identify what was missing, and explain how that affects the first reporting year and the next deadline.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative planning record: reporting period, legal deadline and source checked, planned submission date, actual submission status and assurance obtained. Keep the later emissions timetable separate; confirm it against current CARB guidance.
Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
Illustrative planning record: reporting period, legal deadline and source checked, planned submission date, actual submission status and assurance obtained. Keep the later emissions timetable separate; confirm it against current CARB guidance.
Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
Quality ladder
- Basic
I will report annually from FY2025 and my filing status is pending.
- Better
Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
- Best
Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
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.
Use the current CARB timetable for Scope 1, Scope 2 and Scope 3. Record the reporting period, confirmed deadline, legal source and submission status. Do not derive legal deadlines from a fiscal year or invent an interval between filings.
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.
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.
Real reports
How 3 companies report it
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Host Hotels & Resorts, Inc.
Sands China Ltd.
Cargill
| Field | Host Hotels & Resorts, Inc. | Sands China Ltd. | Cargill |
|---|---|---|---|
| Annual filing flag | Not found | Not found | Not found |
| First reporting year | Not found | Not found | Partial |
| Initial emissions deadline | Partial | Not found | Not found |
| First-year good faith flag | Not found | Not found | Not found |
| Carbon report lag | Not found | Not found | Partial |
| Value-chain start year | Not found | Not found | Not found |
| Filing progress status | Not found | Not found | Not found |
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Advice, not assurance
Framework references
Relevant California requirements and related disclosures
California
SB253-REPORTING-TIMELINE
within California SB 253: Climate Corporate Data Accountability Act
Related & explore
More in California SB 253 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
The page says to prepare seven datapoints: annual filing flag, first reporting year, initial emissions deadline, first-year good faith flag, carbon report lag, value-chain start year, and filing progress status. Use those as the starting checklist before you draft anything.
Use it as a working sequence for getting the disclosure ready, rather than as a final answer key. The page is designed to help you move from data gathering to a draft and then to assurance readiness.
The page includes an evidence pack with five items to support assurance readiness. Build it alongside the disclosure so the claim, the underlying data, and the supporting records stay aligned.
The page says there are six assurance claims to check, each with a claim, risk and evidence angle. Use that section to test whether your draft is supported and whether the evidence pack covers the main risks.
The page lists common reporting gaps and mistakes to watch for. Use that section as a pre-submission check so you can spot missing datapoints, weak evidence, or inconsistent drafting before the disclosure is finalised.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, evidence and draft status so the disclosure is easier to review and hand over.
The Download Centre also includes a printable Library Card in PDF format. It is there as a practical reference you can keep alongside the workbook while you prepare the disclosure.
Yes, but only as a synthetic example to show how the disclosure might look in practice. The page also includes a quantitative table in the example, so you can see how the data may be presented without treating it as a real company disclosure.
The page includes draft-output ideas such as visualisation options, narrative starters and a content-index line. Use those to turn your prepared data into a first-pass disclosure draft.
It gives you the assurance claims to test, the evidence pack to assemble, and the common mistakes to look for. That makes it easier to check whether the draft is internally consistent and backed by records.
The page says ESRS E1 (Climate Change) is the closest correspondence, so the data may be reusable across both contexts. Treat that as a practical cross-framework pointer, not as a statement that the requirements are identical.
More questions this page can help with