The minute
- The California Air Resources Board (CARB) released guidance granting enforcement discretion for the first reporting cycle under SB 253, which applies to companies with revenues exceeding $1 billion doing business in California.
- For the initial reports due November 10, 2026, companies may use existing data for Scope 1 and 2 emissions, and those not already collecting this data may submit a statement of non-reporting on company letterhead instead.
- Although limited assurance is formally required, CARB will accept submissions whether or not assurance has been obtained for the 2026 cycle.
Why it matters
SB 253 represents one of the most expansive mandatory corporate emissions disclosure regimes in the United States. By softening first-year enforcement, CARB signals a pragmatic approach to implementation, giving companies time to build reporting infrastructure before stricter requirements, including Scope 3 value chain emissions, take effect in subsequent years.
CARB will not mandate a specific emissions factor dataset for 2026, and companies can report using existing annual reports, data submitted to other programs, or CARB’s Draft Scope 1 and 2 Template. The board also launched a voluntary intake platform to assist with initial submissions. A separate rulemaking process is underway to establish requirements for 2027 and beyond, covering methodologies, deadlines, assurance standards, and reporting formats, via ESG Today.
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