California Delays First Corporate GHG Reporting Deadline to November 2026

The California Air Resources Board has announced it intends to defer the first reporting deadline for Scope 1 and Scope 2 greenhouse gas emissions under SB 253 from August 10, 2026 to November 10, 2026, while the agency makes limited revisions to implementing regulations and provides a 15-day public comment period before resubmitting a final regulatory package to the Office of Administrative Law. The three-month extension applies to the initial year's required disclosures covering Scope 1 and Scope 2 emissions for the prior fiscal year, with Scope 3 reporting requirements scheduled to begin in 2027 remaining unaffected by the delay. CARB reaffirmed that SB 253 remains fully in effect and that covered companies, defined as US-based businesses with total annual revenues exceeding $1 billion that do business in California, will still be required to report Scope 1 and Scope 2 emissions for the prior fiscal year during 2026.

 

The Regulatory Process Behind the Delay

 

CARB withdrew the climate disclosure regulations previously submitted to the Office of Administrative Law and will issue a new draft containing limited amendments designed to clarify certain reporting requirements before resubmitting the final package. The agency stated that the extension is intended to provide reporting entities with additional certainty regarding their compliance obligations before disclosures become due, acknowledging that many companies have been preparing for the August deadline while awaiting final regulatory clarity on key compliance questions including reporting mechanics, data requirements and administrative procedures. The 15-day public comment period on the revised draft provides affected companies with an important opportunity to engage with CARB's interpretation of specific compliance requirements and to flag practical implementation challenges that the amendments should address before the final regulations take effect.

The withdrawal and resubmission process reflects the practical complexity of implementing one of the most ambitious corporate climate disclosure laws in the United States, where the regulatory detail required to operationalise statutory disclosure requirements at scale across thousands of covered companies inevitably reveals technical and procedural questions that require regulatory clarification before companies can confidently finalise their compliance approaches. Companies that have already invested substantially in emissions data collection, internal governance processes and third-party assurance arrangements should treat the additional three months as an opportunity to validate and refine existing preparations rather than as a signal to pause compliance efforts. The forthcoming amendments may provide important guidance on how CARB expects reporting entities to satisfy their first-year disclosure obligations, making careful monitoring of the comment period and final regulatory release essential for compliance planning.

 

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Implications for Covered Companies and Compliance Readiness

 

The delay affects all US-based companies with annual revenues exceeding $1 billion that do business in California, a scope that captures thousands of large domestic and multinational corporations across every major industry sector. For many organisations that had been racing to complete emissions inventories, establish data collection systems and implement governance and assurance processes by the August deadline, the additional three months provides genuinely valuable runway for refining data quality, validating methodologies and ensuring that Scope 1 and Scope 2 reporting meets the accuracy standards that CARB's regulations will require. The companion climate-related financial risk reporting law SB 261, which requires covered companies to disclose climate-related financial risks, remains stayed pending litigation before the US Court of Appeals for the Ninth Circuit and is therefore unaffected by the CARB announcement.

The practical compliance priorities for companies during the extended window include refining emissions inventories to ensure completeness and methodological consistency, validating data collection systems and internal controls that will support annual reporting going forward, preparing governance frameworks that establish clear board and management oversight of the disclosure process and engaging with the CARB comment process to seek clarification on specific compliance questions. Given that Scope 3 reporting requirements begin in 2027, companies should use the Scope 1 and 2 first-year reporting process as an opportunity to establish the data infrastructure and supplier engagement processes that will be needed for the more complex Scope 3 disclosure, which requires data collection from across the full value chain rather than only from directly controlled operations.

 

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Outlook for California Climate Disclosure Implementation

 

CARB's announcement confirms that California regulators continue to refine the state's climate disclosure framework as implementation deadlines approach, with the limited amendments and regulatory clarifications signal that the agency is responsive to practical implementation concerns raised by reporting entities without retreating from the underlying statutory requirements of SB 253. The California climate disclosure framework remains the most comprehensive mandatory corporate greenhouse gas reporting regime in the United States, requiring both Scope 1 and 2 operational emissions and Scope 3 value chain emissions from large companies operating in the state, creating a disclosure standard that significantly exceeds what the SEC's now-rescinded climate disclosure rules would have required at the federal level. Whether the November deadline holds will depend on the pace of CARB's rulemaking process following the comment period, making monitoring of the regulatory timeline essential for compliance planning teams managing disclosure preparation across multiple jurisdictions.

Sustained implementation of SB 253 through the revised November deadline and subsequent Scope 3 requirements beginning in 2027 would establish California as the de facto US corporate climate disclosure standard, given the scale and economic significance of companies required to report and the likelihood that emissions inventories prepared for California compliance will be adopted for voluntary and other mandatory disclosure purposes simultaneously.