After delaying the reporting deadline by three months, California has finally approved climate disclosure regulations for SB 253. Companies will have until November 10, 2026 to submit reports covering their Scope 1 and 2 emissions. A recent Morgan Lewis memo covers the regulations and provides details:
“The California Office of Administrative Law approved the California Air Resources Board’s initial regulations implementing the state’s corporate greenhouse gas emissions reporting and climate-related financial risk disclosure laws on October 12, making the regulations immediately effective. The approval completes the administrative review process and formally establishes November 10, 2026 as the first-year reporting deadline under Senate Bill 253. Covered companies are subject to the initial Scope 1 and Scope 2 emissions reporting requirements by that date, consistent with CARB’s first-year reporting guidance.”
California regulators have indicated that first-year reporting will be lightly scrutinized. The California Air Resources Board (CARB) is looking for companies to make good-faith efforts to comply. Alternatively, 2027 may be a different story. CARB has indicated that new reporting rules are coming. 2027’s rules are expected to introduce more stringent requirements, which will bolster reporting quality and increase compliance complexity.
SB 253’s companion law, SB 261, will require climate-related financial disclosures in addition to GHG metrics. SB 261 is currently enjoined by the Ninth Circuit Court of Appeals. The Court’s Opinion is still pending after oral arguments were heard over ten months ago. SB 261 reporting was originally slated to begin alongside SB 253, meaning that 2027 could see SB 261’s requirements reintroduced depending on litigation timelines and outcomes.
Our members can learn more about climate disclosure regulations here.
