California’s first corporate climate reporting deadline is finally final. Here is what happened in October and what comes next.
Link to The corporate climate reporting deadline is official. The corporate climate reporting deadline is official.
- The regulation is final. As anticipated, on October 12, California’s Office of Administrative Law approved CARB’s Initial Regulation under SB 253, and it took effect that day. CARB’s notice confirms November 10, 2026, as the first annual reporting deadline.
- Who is covered? SB 253 applies to U.S. entities that do business in California and have more than $1 billion in annual revenue. No Scope 3 reporting is required this year.
Link to What is due by November 10? What is due by November 10?
- Please see our previous post about what is due by November 10.
Link to Inside CARB’s October 22nd meeting Inside CARB’s October 22nd meeting
- Staff update. At the meeting, CARB staff reported on their regulatory and engagement work to date, and the board spent considerable time on Scope 3.
Link to What comes next What comes next
- Upcoming reports will be public. CARB staff aims to post the outcome of this year’s reporting within 90 days after November 10. Emissions reports and statements of non-reporting will be made public.
- Fees. CARB intends to start issuing annual fee notices on December 10, 2026, with payment due within 60 days.
- The 2027 rules. CARB plans another public workshop before a staff report and draft regulation.
- Litigation. The Ninth Circuit granted an injunction for SB 261 while the appeal is pending, but not for SB 253. A final merits decision from the Ninth Circuit remains pending.
Bottom line for companies to comply with SB 253: File by November 10. Keep in mind that whatever you file will be public and start planning now for Scope 3 in 2027.
If you have questions about this deadline and want more details on how you can prepare, please contact the author.