California Proposes Delay to First SB 253 Reporting Deadline
California’s SB 253 is entering its first implementation phase, with CARB now proposing extra time for the initial Scope 1 and Scope 2 reporting cycle. The update leaves the reporting requirement in place, with timing and enforcement discretion shaping the first-year cycle and assurance remaining relevant for later implementation.
The California Air Resources Board (CARB) is proposing to defer the first Scope 1 and Scope 2 greenhouse gas emissions reporting deadline under Senate Bill 253 from 10 August 2026 to 10 November 2026. The change would give covered companies more time while CARB finalises the implementing regulation.
The open point is the final implementation date, which now depends on CARB’s 15-day change process and approval by the Office of Administrative Law (OAL), the California body that reviews state agency regulations before they take effect.
What CARB Announced
On 24 June 2026, CARB said it is updating its regulatory proposal for the California Corporate Greenhouse Gas Reporting Program. The update would defer the first reporting deadline by three months and add limited clarifications to the proposed requirements.
The change relates to the Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation. CARB’s Board approved the Initial Regulation on 26 February 2026, and the final package was submitted to OAL on 20 May 2026 before being withdrawn for limited clarifying changes.
Background: SB 253
Senate Bill 253 is the Climate Corporate Data Accountability Act. It requires covered companies to report greenhouse gas emissions annually for the prior fiscal year.
The law applies to U.S.-based companies with total annual revenues above US$1 billion that do business in California. Reporting entities must disclose Scope 1, Scope 2 and Scope 3 emissions. The first 2026 reporting cycle covers Scope 1 and Scope 2; Scope 3 reporting starts in 2027.
SB 253 creates the legal reporting duty; CARB’s Initial Regulation sets the first implementation framework, including the first-year reporting date.
Status and Enforcement
CARB’s first-cycle position concerns enforcement discretion. For the 2026 report, reporting entities may submit Scope 1 and Scope 2 emissions data based on information they already had or were already collecting when CARB issued its December 2024 Enforcement Notice.
If an entity was not collecting Scope 1 and Scope 2 data, and did not plan to collect it at that time, CARB does not expect Scope 1 and Scope 2 reporting data for the first reporting cycle. Instead, the entity should submit a statement on company letterhead explaining that, in accordance with the Enforcement Notice, it is not submitting emissions data because it was not collecting, and did not plan to collect, the relevant data when the notice was issued.
Assurance in the First Cycle
SB 253 includes an independent third-party assurance requirement for emissions disclosures. However, CARB’s March 2026 workshop materials state that limited assurance is not required for the 2026 Scope 1 and Scope 2 submission.
For 2026 reporting, entities may submit Scope 1 and Scope 2 data based on information they already had or were already collecting when CARB issued its December 2024 Enforcement Notice, whether or not that data received limited assurance.
Assurance remains relevant beyond the first cycle. CARB’s workshop materials discuss limited assurance for Scope 1 and Scope 2 in annual reporting after 2026, so assurance readiness remains part of the continuing SB 253 implementation framework.
Separate Position on SB 261
California’s climate disclosure framework also includes Senate Bill 261, which covers climate-related financial risk reporting. CARB describes this programme as applying to public and private U.S. companies doing business in California with annual revenues above US$500 million.
SB 261 is in a different position. CARB’s December 2025 Enforcement Advisory states that, following a court order, the agency will not enforce the SB 261 reporting deadline while appellate proceedings are pending. Companies may report voluntarily at this stage.
The proposed 10 November 2026 date therefore concerns SB 253 emissions reporting, not SB 261 climate risk reporting.
Reporting Relevance
The proposed deadline change is practical rather than structural. Companies likely to fall within SB 253 would have more time before the first Scope 1 and Scope 2 filing, but they still need to prepare for public emissions disclosure.
CARB describes the programmes as a way to provide clearer and more consistent information to consumers and investors. For reporting teams, this brings emissions data into a more formal disclosure process, with implications for data ownership, controls and assurance.
What to Watch Next
The next procedural step is CARB’s release of limited changes to the Initial Regulation for a 15-day public comment period. After that, CARB plans to re-submit the package to OAL.
Until that process is complete, 10 November 2026 should be treated as a proposed working date, not a final deadline. Companies likely to be in scope should use the additional time to confirm coverage, review available Scope 1 and Scope 2 data, and document whether they are submitting emissions data or a statement under CARB’s first-cycle enforcement approach.
