California Finalizes SB 253 Rules, Confirming November 10 Corporate Climate Reporting Deadline

The California Office of Administrative Law (OAL) approved the state’s initial corporate climate disclosure regulation on 12 October 2026, confirming 10 November as the deadline for the first greenhouse gas emissions reports under Senate Bill 253 (SB 253). The approval completes the final regulatory step for the initial rules and comes as the California Air Resources Board (CARB) has sent reminder letters to companies that may fall within the reporting requirements.

 

SB 253 generally applies to US-formed business entities with annual revenues exceeding $1 billion that do business in California. For the first reporting cycle, companies must disclose Scope 1 and Scope 2 greenhouse gas emissions, covering direct emissions and indirect emissions associated with purchased energy. Scope 3 value chain emissions are scheduled to enter the reporting requirements in subsequent years. CARB has also introduced first-year relief measures, including options for companies that did not possess or collect the relevant emissions information by 5 December 2024, and flexibility around limited assurance for 2026 submissions.

 

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The approval does not resolve the separate legal challenge to California’s climate disclosure laws. The Ninth Circuit Court of Appeals issued an injunction against enforcement of SB 261 in November 2025 while the appeal proceeds. SB 261 requires qualifying companies with more than $500 million in annual revenue to disclose climate-related financial risks and measures to address them. The court declined to block SB 253, allowing the initial greenhouse gas reporting requirements to proceed. Companies therefore need to distinguish between the emissions reporting deadline under SB 253 and the separate legal status of SB 261.

 

CARB previously identified more than 4,000 companies as potentially covered by the laws. With the November deadline approaching, businesses should assess whether they meet the SB 253 criteria, determine which emissions information they can report and review the available first-year reporting options. CARB’s voluntary intake platform can be used to submit emissions reports and company information, while submissions can also be sent by email.