As promised at its last public workshop on implementation of Senate Bill 253 (SB 253), the Climate Corporate Data Accountability Act, the California Air Resources Board (CARB) has today provided supplemental guidance for the first round of GHG reporting under SB 253, including a voluntary online intake platform for fee contact information and greenhouse gas (GHG) emissions reporting, an instructional video, and a companion guidance document. The reports for 2026 are due on or before November 10, 2026.
For companies in scope of SB 253, those doing business in California with total annual revenues exceeding $1 billion for two consecutive years, here is what you need to know:
- As previously noted, CARB is taking a flexible approach for 2026 reporting and will exercise enforcement discretion to allow companies to report based on data they already had or were collecting as of December 2024 Enforcement Notice (whether or not the data received limited assurance).
- Companies that were not collecting emissions data or not planning to collect emissions data as of the December 2024 Enforcement Notice are not expected to report in 2026, but should submit a non-reporting statement on company letterhead before the November 10, 2026, deadline (these companies will need to report Scopes 1, 2, and 3 beginning in 2027).
- 2026 GHG reports and statements of non-reporting may be submitted through CARB’s voluntary online platform or by emailing climatedisclosure@arb.ca.gov before the November 10 deadline.
- Acceptable formats for the 2026 reports include: (1) an existing annual report with Scopes 1 and 2 data, (2) data reported to other programs/voluntary initiatives, or (3) CARB’s draft template for reporting Scopes 1 and 2 data.
- Only annual Scopes 1 and 2 totals are required for this first round of reporting, though CARB encourages reporting entities to provide additional detail such as description of methodologies, data sources, global warming potential values, emissions factors, organizational boundaries, disaggregated emission data by category and gas, and any assumptions used to help qualify the reported emission numbers and provide important context (companies may refer to CARB’s draft template for examples).
- No specific emissions factor dataset is mandated for 2026 reporting. Reporting entities may use the most recent eGRID 2023, the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative, or other credible sources, and are encouraged to identify the emission factors used and their sources.
- Although SB 253 requires limited assurance beginning in 2026, CARB will accept submissions with or without assurance for this first cycle (as described in Question 20 of its FAQs).
- CARB is developing requirements for 2027 and beyond through a second rulemaking.