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London Reporting Academy California SB 253 · Climate Corporate Data Accountability Act · Disclosure SB253-REPORTING-TIMELINE

Reporting timeline and filing status

SB253-REPORTING-TIMELINE · mandatory · metrics + narrative

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.

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.

  • Annual filing flag

    Sustainability reporting

    Whether 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.

  • First reporting year

    Finance

    The 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.

  • Initial emissions deadline

    Sustainability reporting

    The 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.

  • First-year good faith flag

    Legal

    Whether 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.

  • Scope 3 timing basis

    Sustainability reporting

    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 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.

  • Value-chain start year

    Sustainability reporting

    The 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.

  • Filing progress status

    Sustainability reporting

    The 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?
+ Show SB253-REPORTING-TIMELINE sub-elements (LRA working checklist)

How to prepare it

Confirm 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.
Set 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.
Check whether the first year allows a good-faith initial submission, and keep evidence showing how that judgement was reached.
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.
Identify 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.
Keep 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 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

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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.
+ Show 5 more

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.
+ Show 4 more

Examples

How it reads on the page

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

Illustrative (synthetic) example — manufacturing

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 (synthetic) example — financial services

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.

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 →

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.

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 →

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.

Real published reports

Host Hotels & Resorts, Inc.

Related

Real Estate · United States · 2025 · p.62 ↗

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.

Related

Hotels, Restaurants, Leisure, Tourism Services · Macao · 2025 · p.26 ↗

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

Related

Food Production — Agricultural · United States · 2025 · p.14 ↗

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).
FieldHost Hotels & Resorts, Inc.Sands China Ltd.Cargill
Annual filing flagNot foundNot foundNot found
First reporting yearNot foundNot foundPartial
Initial emissions deadlinePartialNot foundNot found
First-year good faith flagNot foundNot foundNot found
Carbon report lagNot foundNot foundPartial
Value-chain start yearNot foundNot foundNot found
Filing progress statusNot foundNot foundNot found

Full evidence map with quotes and page numbers →

✓ Knowledge Hub AI Assistant · Human-in-the-loop
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Framework references

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SB253-REPORTING-TIMELINE

within California SB 253: Climate Corporate Data Accountability Act

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