CARB Adjusts Timeline for Climate Disclosure Framework under SB 253 and SB 261
CARB continues to shape its corporate climate disclosure landscape, reflecting progress in framework design and adjustments to implementation timelines under the state’s landmark climate reporting laws.
The California Air Resources Board (CARB) has adjusted its timeline for developing the state’s climate disclosure framework while continuing to expand the regulatory groundwork established under Senate Bills 253 and 261. During the autumn 2025, the Board issued preparatory materials to help organisations interpret upcoming requirements, including a Climate-Related Financial Risk Report Checklist and a Preliminary List of Regulated Entities accompanied by a stakeholder survey. These resources were designed to clarify the scope of reporting and support companies in evaluating their exposure to climate-related financial risks.
October Developments and the Draft Scope 1 and 2 GHG Reporting Template
On 10 October 2025, CARB published the Draft Scope 1 and 2 GHG Reporting Template, marking a significant procedural step towards implementation under the Climate Corporate Data Accountability Act (SB 253). The draft template structures the disclosure of direct and indirect emissions and provides detailed guidance on the information companies will be expected to report. It requires entities to specify calculation methodologies, activity data and emission factors, reflecting an emphasis on transparency and consistency. The use of this draft template will remain voluntary during the initial reporting cycle in 2026, allowing organisations to familiarise themselves with the disclosure format before full implementation.
The document is open for public consultation until 27 October 2025 through CARB’s public docket. The agency invites input from regulated entities, voluntary reporters and other stakeholders to ensure the template is practical across sectors with diverse operational profiles.
Postponed Rulemaking and Stakeholder Engagement
In its October notice, CARB acknowledged the substantial volume of feedback received since the August 2025 workshop. Given the scale of responses and ongoing discussions regarding the range of covered entities, the Board has postponed the presentation of the initial rulemaking package, including fee-related provisions, from late 2025 to the first quarter of 2026. The delay allows additional time to incorporate stakeholder input and refine technical and administrative elements before finalisation.
Stakeholders may submit comments on the draft template via the public docket, provide feedback on the preliminary list of entities through an online survey, or send general inquiries to CARB’s climate disclosure team. Such engagement is intended to refine technical details before the formal adoption of reporting requirements.
Outlook
The sequence of publications across September and October illustrates CARB’s effort to advance preparatory work while adjusting its regulatory timeline to ensure clarity and feasibility. Each release builds on the previous one, forming a coherent framework that prepares organisations for compliance under SB 253 and SB 261. The forthcoming rulemaking phase in early 2026 is expected to finalise disclosure procedures and integrate lessons from this consultation round.
California’s methodical and transparent approach reinforces its position as a regulatory leader in climate-related reporting. By combining progress with flexibility, CARB is setting a balanced precedent for credible and effective disclosure that aligns with both state and international expectations.
