In 2023, Governor Newsom signed two landmark climate disclosure laws — CA SB 253 and CA SB 261. SB 253 requires companies doing business in California with total revenues over $1 billion to annually report their Scope 1, 2, and 3 carbon emissions. Separately, SB 261 requires companies doing business in California with total revenues over $500 million to submit biennial public climate-related financial risk reports to the state.  

Even with both laws containing deadlines in the first half of 2026, CARB still has not started the formal rulemaking process. At their August 21 Public Workshop, the California Air Resources Board (CARB) indicated the following deadlines: 

  • A target due date of June 30, 2026, for initial scope 1 and 2 reports pursuant to SB 253 (Initial scope 3 emissions reports will be due in 2027 on a date to be determined by CARB) 
  • A due date of January 1, 2026, for initial climate risk reports pursuant to SB 261 
  • An upcoming notice of proposed rulemaking for SB 253 and SB 261 on October 14, 2025, followed by a 45-day public comment period, and official Agency consideration on December 11th and 12, 2025 

On July 9th, CARB released this FAQ Document containing updates on the agency’s implementation of SB 253 and SB 261. The FAQ document cites a notice of enforcement discretion from December 2024 for SB 253. CARB has reiterated that they won’t find any company that makes a good faith effort to comply in violation of the law for the first year of reporting.