The California Air Resources Board (CARB) voted to approve the implementing regulations for the Climate Corporate Data Accountability Act (CA SB 253)  and the Climate-Related Risk Disclosure Act (CA SB 261).  

  • SB 253 requires companies with revenues that exceed $1 billion and do business in California to report their Scope 1 and 2 emissions beginning August 10, 2026, and Scope 3 emissions beginning in 2027.   
  • SB 261 requires companies doing business in California with revenues that exceed $500 million to submit biennial public climate-related financial risk reports to the state beginning January 1, 2026.  

The Regulations establish CARB’s fee structure for SB 253 and SB 261 and define key concepts relevant to determining the entities in-scope of the laws, such as what it means to “do business in California”. In addition, the regulations set an August 10, 2026, deadline for the initial scope 1 and 2 emissions reports due under SB 253. CARB announced that it will begin a separate rulemaking on GHG emission reporting requirements for 2027 and onwards, which includes the initial scope 3 emissions disclosures.  

Importantly, compliance with SB 261 is currently voluntary, as a federal court issued an injunction blocking its enforcement while it hears a court case. Over 120 companies have voluntarily submitted reports to the public docket. The injunction does not apply to SB 253. 

ISPA will continue to monitor the implementation of SB 253 and 261, as well as the legal challenges to either law.