The deadline for California’s first year of GHG reporting under SB 253 is quickly approaching. Initial reports are due August 10, 2026. The California Air Resources Board indicated that enforcement will be relaxed for this year’s reports, and companies that make a good faith effort to comply with the law are likely to face little scrutiny. A recent Wilmer Hale memo gives a refresher on SB 253’s reporting requirements:
“By August 10, 2026, companies doing business in California with over $1 billion in annual revenue must submit their first GHG emissions reports under SB 253. First-year reports will cover Scope 1 and Scope 2 emissions only; Scope 3 reporting is not required until 2027. The California Air Resources Board (CARB)—the agency tasked with implementing and enforcing the state’s climate disclosure laws—has stated that it will exercise enforcement discretion for good faith first-year submissions. Companies that were not collecting emissions data when CARB issued its December 2024 enforcement notice are not required to report, but each such company must submit to CARB a statement on company letterhead stating that it will not provide a 2026 report for this reason. These companies will need to begin reporting in 2027.”
Climate-related risk reporting under SB 261 is currently enjoined by the courts. However, that injunction did not extend to GHG reporting requirements under SB 253. Draft guidance from CARB is still pending, so this year’s reports aren’t expected to be fully standardized.
Our members can learn more about GHG disclosures here.
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