The California Air Resources Board (CARB) released new guidance on Sept. 2 giving companies additional flexibility as they prepare for the state's first greenhouse gas emissions reporting deadline on Nov. 10.
California's SB 253 requires companies with more than $1 billion in annual revenue that do business in the state to report their Scope 1 emissions — those produced directly by the company — and Scope 2 emissions — indirect emissions from purchased energy — during the first reporting cycle.
CARB said it would "exercise enforcement discretion" during the 2026 reporting cycle. Companies may use Scope 1 and Scope 2 emissions data from their previous fiscal year based on information they already had or were collecting when CARB issued an enforcement notice in December 2024. Companies that were not collecting or planning to collect the data at that time may instead submit a statement on company letterhead stating that they will not report emissions data during the first cycle.
CARB will also accept several reporting formats, including existing annual reports, emissions data submitted to other programs or voluntary initiatives, and CARB's draft reporting template. The agency will accept 2026 submissions regardless of whether companies have obtained limited assurance, an independent review intended to provide confidence in the reported information.
The guidance gives companies more flexibility in complying with California's first emissions reporting requirements while CARB continues developing its longer-term regulations. Companies can rely on existing emissions data and reporting formats rather than immediately adopting a single state-prescribed approach, and some companies that had not begun collecting emissions data by December 2024 will not have to provide that data during the first reporting cycle.
CARB previously said it planned to use enforcement discretion during the first reporting cycle because it "recognizes that companies may need some lead time to implement new data collection processes" necessary to fully report their Scope 1 and Scope 2 emissions.
The relief applies to the initial reporting cycle. CARB is developing requirements for 2027 and subsequent years through a rulemaking process covering greenhouse gas accounting methods, reporting deadlines, assurance requirements, and reporting formats.
Governor Gavin Newsom (D) signed SB 253 in October 2023. It requires certain companies doing business in the state to report Scope 1, Scope 2, and eventually Scope 3 emissions, which include indirect emissions throughout a company's value chain.
CARB originally set Aug. 10, 2026, as the first deadline for companies to report Scope 1 and Scope 2 emissions. The agency later moved the deadline to Nov. 10 while it revised its implementing regulations. A CARB representative said the new deadline "will help ensure reporting entities have additional clarity following approval of the final regulation before reporting is due." CARB released a preliminary list identifying more than 4,000 companies that could be subject to the requirements.
Newsom also signed SB 261 in 2023. It requires certain companies with more than $500 million in annual revenue to disclose climate-related financial risks. The U.S. Court of Appeals for the Ninth Circuit temporarily blocked enforcement of SB 261 in November 2025 while litigation over the law continues.
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