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California SB 253: Climate Corporate Data Accountability Act · 2026-initial-regulation-as-amended-sb219
Disclosure SB253-SCOPE-1

Scope 1 greenhouse gas emissions

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 asks an organisation to report its direct greenhouse gas emissions from sources it owns or controls. In practice, that means the emissions created by the organisation’s own activities, such as fuel burned in company vehicles, boilers, generators or other on-site equipment, rather than emissions from suppliers or customers.

The practical focus is on the organisation’s full operational footprint, not just a few prominent sites. Teams should think about where direct emissions arise across the business and make sure the reporting boundary is applied consistently so the figure reflects the organisation’s own operations as a whole.

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
Boundary for emissions State which parts of the business are included when compiling the direct-emissions figure, so the reporting perimeter is clear and consistent. Group structure chart, consolidation memo, boundary policy, list of included entities/sites. Finance / Sustainability reporting
Calculation approach Describe the method used to turn activity data into the direct-emissions total, including the main assumptions and emission factors applied. Calculation workbook, methodology note, emission factor source file, assumptions log. Sustainability / Environmental data
Reporting timeframe Specify the exact time window covered by the direct-emissions figure, including start and end dates used for the report. Reporting calendar, period-end close pack, emissions data extract dates, management reporting timetable. Finance / Reporting
Emission activity sources List the operational sources that feed into the direct-emissions figure, such as fuel use or other on-site combustion sources, as applicable to the business. Source inventory, meter list, fuel purchase records, site operations logs, asset register. Operations / Sustainability
Direct emissions total Enter the full direct-emissions amount for the reporting period, expressed in tonnes of carbon dioxide equivalent. Final emissions calculation file, reviewed consolidation schedule, sign-off pack, source data extracts. Sustainability / Finance
+ Show SB253-SCOPE-1 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting perimeter first: decide which parts of the business are included in the Scope 1 figure, and keep that boundary definition on file.
2List the direct emission sources that sit inside that perimeter, using a clear internal inventory so you can show what was counted.
3Choose and record the calculation approach you used, so the method behind the number is traceable and can be checked later.
4Confirm the reporting year or period covered, and make sure the emissions total matches that exact timeframe.
5Compile the supporting evidence for the boundary, sources, method and total, then prepare the Scope 1 emissions figure in tCO2e or a clear narrative where the data point calls for text.
6Document any exclusions, restatements or boundary changes, and then compare the final submission against the official source to confirm the disclosure is complete and consistent.
Request the data

Request the Scope 1 emissions pack from EHS / Operations

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

What is our total direct greenhouse gas emissions figure for the reporting year, and what boundary, method, period and source list support it?

Use your organisation’s own terms first for the team, systems and asset groups involved, then map them to the reporting labels in the pack. Keep the ask in business language your colleagues already use, and check the source material before sign-off.

Weak request

Please provide the Scope 1 evidence for the disclosure.

Why it fails: It uses framework language only, so the owner may not know which team records, systems or assets to pull. It also does not say what period, sources, method or total should be included, so the response may be incomplete or hard to verify.

Better request

Please send the direct emissions pack for [reporting year] from your team’s records. Include the period covered, the sites/assets/fuel streams included, the calculation approach, the total in tCO2e, and the source extracts or workbook used to build it. Please use your team’s own names for the categories and add any estimate or exclusion notes.

Formal email template
Subject: Request for direct emissions data pack for [reporting year]

Hi [name/team],

Could you please send over the data pack for our direct emissions figure for [reporting year]?

Please include:
- the boundary used for the figures
- the method used to calculate the total
- the reporting period covered
- the list of emission sources included
- the total emissions value in tCO2e
- the source files or system extracts used to build the numbers
- any notes on estimates, exclusions or changes from the prior year

Please also confirm the version date and who prepared the pack.

If helpful, you can use the attached response form. 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/team] — could you send the direct emissions pack for [reporting year]? Please include the boundary, method, period, source list, total tCO2e, source extracts and any estimate/exclusion notes. Please adapt this to your organisation’s own terms and check the source material before sign-off. Thanks.
Industry examples
Manufacturing

Context. A plant with boilers, furnaces, backup generators and a company van fleet.

Adapted request. Please send the direct emissions pack for [reporting year] covering the plant, warehouse and fleet records. Include the fuel logs, generator run data, refrigerant records, the calculation workbook, the total tCO2e and any exclusions or estimates.

Example response. Attached: plant fuel ledger, fleet card extract, refrigerant log, emissions workbook v4, total direct emissions 12,480 tCO2e, with backup generator estimates flagged in notes.

Property / Real Estate

Context. A portfolio with offices, landlord-controlled plant and tenant areas.

Adapted request. Please send the direct emissions pack for [reporting year] covering landlord-controlled energy systems and any company-owned vehicles. Include the building list, meter extracts, refrigerant records, calculation method, total tCO2e and any sites excluded from the total.

Example response. Attached: portfolio boundary note, meter export, chiller maintenance log, vehicle fuel extract, calculation file v2, total direct emissions 3,210 tCO2e, with one leased site excluded and explained in the notes.

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

State which parts of the business were included in the calculation, name the approach used to quantify the figures, and note the time window covered by the data.

Context note

Explain that the figures represent the organisation’s direct climate impact from the activities counted in the inventory, rather than a wider value-chain view.

Fluctuation statement

If the total moved materially, point to the main operational drivers, changes in included sources, or any shift in the calculation basis that affected the result.

Content index entry
SB253-SCOPE-1 Scope 1 greenhouse gas emissions — [location / page] / [notes]
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Preparation tools & forms

Professional preparation tools for SB253-SCOPE-1 — 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.

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Go deeper · SB253-SCOPE-1
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
I prepared the coverage figure using the group structure and control position that applied in the reporting year, and I checked whether any acquisitions, disposals or other structural moves changed what should be included.The assurer will test whether the boundary was set consistently, whether all relevant owned or controlled sources were brought in, and whether changes in the business were reflected correctly.Group structure chart; legal entity and operational control mapping; acquisition/disposal register; boundary memo; year-end consolidation papers; management sign-off on inclusion/exclusion decisions.
I treated the disclosed operations as covering sources we own or directly run, wherever they sit geographically, and I documented any exclusions with a clear reason.The assurer will probe whether the scope is complete across locations and whether any omitted sources were left out for a defensible reason rather than convenience.Asset and site register; control assessment; list of included and excluded sources; rationale for exclusions; site-level inventory; internal review notes.
I calculated the figure using the accounting approach we selected for this disclosure, and I kept the working papers showing how the method was applied to the underlying activity data.The assurer will check whether the chosen method matches the stated reporting basis and whether it was applied consistently to all relevant data.Methodology paper; calculation workbook; emission factor source list; activity data extracts; version history; reviewer comments and approvals.
I reviewed whether business changes during the year affected the way the number was built, and I adjusted the calculation basis where those changes would otherwise distort the result.The assurer will look for evidence that structural changes were identified, assessed and reflected in the calculation rather than ignored.M&A and restructuring papers; change log; recalculation memo; prior-period comparison analysis; management review evidence.
I used the prior fiscal year as the reporting period for the disclosed number and checked that the dates in the supporting files matched that period.The assurer will test whether the figure relates to the correct year and whether the source data and final disclosure are aligned to that period.Reporting calendar; period-end data extracts; ledger or operational reports for the year; reconciliation to the disclosed period; sign-off pack.
I listed the direct emission sources that fed into the total, and I kept a source inventory that ties each item back to the underlying site or asset.The assurer will probe completeness of the source list and whether each source can be traced to a real operational basis.Source inventory; site/asset register; mapping from sources to locations or equipment; inclusion/exclusion rationale; supporting operational records.

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 asked first
The request goes to a team that does not hold the fuel, fleet, or site records, so the data chase starts with people who cannot confirm the numbers.
Framework language used too early
Staff ask for the figure in reporting jargon instead of the business terms used on the ground, which leads to mismatched answers and extra rework.
Boundary never pinned down
No one agrees which parts of the business sit inside the data pull, so some sites or assets are included twice while others are left out.
+ Show 6 more

Where judgement is often needed

Acquisitions, disposals, and other boundary shifts
If the business has bought, sold, or restructured operations during the period, set out which sites and activities sit inside the reporting perimeter for the year and explain any change from the prior year basis.
Different country rules for the same activity
Where local reporting or operational definitions differ across jurisdictions, choose one consistent company basis for deciding what counts in scope and explain that basis clearly.
Borderline sources and shared operations
For assets or activities that sit near the edge of the perimeter, decide whether they are included or left out using a documented control or ownership logic, and describe the treatment of any shared or jointly run sources.
+ Show 7 more
Examples

Illustrative examples

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

Illustrative (synthetic) example — manufacturing

We report for our consolidated operations covering 1 January to 31 December 2025, and the figures below relate to the sites and activities we control in that period. - We used an activity-based approach with emission factors to convert fuel use and other direct sources into tonnes of CO2e. - Our direct emissions came from gas-fired boilers, company vehicles, and on-site backup generators. - For this reporting year, our total direct greenhouse gas emissions were 18,400 tCO2e.

This example shows a first-person narrative disclosure that identifies the reporting year, explains the boundary in plain terms, names the main direct sources, and states the calculation approach and total.

Illustrative (synthetic) example — food and beverage

Our disclosure covers the full year from 1 April 2025 to 31 March 2026 and includes the business units and facilities we operate and control. - We estimated direct emissions using measured fuel consumption and standard conversion factors. - The main sources were refrigeration leaks, natural gas used in processing, and delivery vans. - Our total direct greenhouse gas emissions for the period were 9,750 tCO2e.

This example uses different wording and a different sector while still showing the period covered, the organisational boundary, the method used, the direct sources included, and the total direct emissions.

Company reportsReal published reports
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How companies report SB253-SCOPE-1 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 a specific total for Scope 1 greenhouse gas emissions, reporting 92,608 MT CO2e on page 54. The report also mentions Scope 2 and Scope 3 emissions categories on the same page, with some reference to Scope 3 emissions and science-based targets on page 18. However, the report does not include clear information on the Scope 1 boundary, calculation method, reporting period, or emission sources, as no quotable evidence was found for these datapoints.
C.H. Robinson
Air Freight Transportation and Logistics · United States · 2025
Open report →
C.H. Robinson's 2025 Sustainability Report provides total Scope 3 greenhouse gas emissions data for multiple years, with figures such as 17,811,002 mTCO2e reported on page 62. The report also references greenhouse gas emissions for Scope 1, 2, and 3 in general terms on page 20, indicating coverage of these categories. However, specific details on Scope 1 emissions—including boundary, calculation method, reporting period, sources, and total emissions—are not found or unclear in the report.
Bank of America
None · United States · 2025
Open report →
Bank of America's 2025 sustainability report provides some contextual information on Scope 1 greenhouse gas emissions, including references to emissions units and years such as 2010 baseline through 2024 on page 20, and mentions coverage of Scope 1, 2, and 3 emissions on pages 18 and 28. The report also discusses organizational boundaries for GHG emissions reporting and includes sector-specific references like maritime shipping and auto manufacturing on pages 23 and 24. However, the report lacks clear, quotable disclosures on the Scope 1 boundary, calculation methods, reporting period, sources, and total emissions, with these datapoints either unclear or not found in the document.
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Scenarios to work through

A manufacturing group runs one UK site and two overseas depots. The sustainability team has emissions from gas boilers, company vans and backup generators, but the finance team is unsure whether to include a leased warehouse where the group does not control fuel use.

QHow should the preparer decide which sources belong in the Scope 1 boundary for this disclosure?
Reveal model answer →

A retailer has calculated direct emissions using fuel purchase records for its fleet and gas meters for its stores. The team also has an estimate for refrigerant leaks, but the working papers do not explain how the estimate was built.

QWhat should the preparer check before relying on the calculation for Scope 1 emissions?
Reveal model answer →

A group reports on a calendar-year basis, but one business unit has prepared direct emissions for its own financial year ending 31 March. The consolidated pack also includes a total for the previous 12 months, but no one has confirmed which period the disclosure should cover.

QWhich reporting period should the preparer use for the Scope 1 disclosure?
Reveal model answer →

An industrial company has direct emissions from boilers, owned delivery trucks and a small on-site generator. The draft note gives a total of 18,400 tCO2e, but it does not say which sources were included, and the team is unsure whether to mention all source types or only the largest ones.

QWhat should the preparer do about the source description and the total?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

California
SB253-SCOPE-1
within California SB 253: Climate Corporate Data Accountability Act
Open official source →
Primary
Related & explore
Go deeper · SB253-SCOPE-1
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

SB253-SCOPE-1: what do I need to gather before I start drafting the disclosure?+
How do I set the emissions boundary for SB253-SCOPE-1 using this page?+
What calculation approach should I use for the SB253-SCOPE-1 disclosure page?+
What reporting timeframe should I use for SB253-SCOPE-1 and how do I show it clearly?+
Who should own the SB253-SCOPE-1 data collection and sign-off process?+
What evidence should I keep for SB253-SCOPE-1 so the disclosure is assurance-ready?+
What are the common mistakes or reporting gaps on the SB253-SCOPE-1 page?+
How do I use the SB253-SCOPE-1 workbook download to prepare the disclosure?+
What can I take from the SB253-SCOPE-1 illustrative example disclosure when drafting my own?+
Can I reuse SB253-SCOPE-1 data for ESRS E1 (Climate Change) reporting?+
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