Status Update on CARB’s Corporate GHG Reporting Program
On September 1, 2026, California Air Resources Board (“CARB”) staff released a guidance document for entities who are preparing to submit 2026 Scope 1 and 2 greenhouse gas (“GHG”) emission reports as required under Senate Bill (“SB”) 253. SB 253, also known as the Climate Corporate Data Accountability Act, requires entities doing business in California with more than $1 billion in total annual revenue to disclose Scope 1, 2, and 3 GHG emissions. Its companion legislation, SB 261, requires companies with total annual revenue exceeding $500 million to disclose their GHG emissions.
Since 2024, in implementing SB 253 and SB 261, CARB staff has been developing draft regulations, holding workshops, and defending lawsuits seeking to enjoin its enforcement. Lawsuits filed by the U.S. Chamber of Commerce and by ExxonMobil argue SB 253 violates the First Amendment and exceed California’s authority as a state. While the companion legislation, SB 261, has been under an enforcement stay, SB 253 remains in effect. The Ninth Circuit heard arguments in January 2026, but no decision has yet been issued at this time.
In the interim, CARB has proceeded forward with reporting deadlines and regulatory changes. Draft regulations were first issued in December 2025, followed by public hearings and workshops, before being submitted to the Office of Administrative Law for final approval in May 2026.
In a June 2026 bulletin and a July 2026 workshop, CARB staff announced that the draft regulations were withdrawn for further clarifying changes and would be resubmitted once those changes were made. As part of the deferral, the deadline for reporting Scope 1 and 2 emissions was extended to November 10, 2026. The workshop expanded the parameters for GHG reporting, including proposals for GHG disclosures and guidance, drawing from corporate standards and California’s Mandatory Reporting Regulation. CARB has repeatedly stressed that this first round of emissions reporting is voluntary, in part because the program is still under development and in part due to the legal challenges brought against its enforcement.
The September 1 guidance document provides information intended to assist reporting entities ahead of the November 10 voluntary reporting deadline. It outlines how to locate the agency’s voluntary intake platform, explains reporting requirements and directions on the level of detail required in entities’ reports, and reflects CARB’s discretion over enforcement of and compliance with SB 253. It also reiterates that the 2026 reporting is voluntary, pending the outcome of the various legal proceedings.
The withdrawn regulations have not yet been resubmitted for approval, but it is likely that CARB will do so soon. CARB is also internally underway with a second rulemaking process for the 2027 and subsequent reporting years. This rulemaking will define mandatory reporting requirements, and will envelop all three categories of emissions reporting for the prior fiscal year by November 10 of the reporting year.
For more information, contact Brian Biering or Clarissa Maloney.