The California Air Resources Board (CARB), the regulator charged with developing and enforcing new regulations requiring large companies to disclose their value chain emissions and report on climate-related financial risks, revealed that it will push off the initial rulemaking for the new climate reporting regulation into early next year.
According to the CARB notice, under the proposed updated timeline, the initial rulemaking, previously anticipated for October 2025, will be presented in Q1 2026. CARB said that the delay is being made in light of the large volume of public comments on recently issued resources related to the new regulations and “ongoing input related to identifying the range of covered entities.”
While the update did not indicate a change in timelines for the beginning of reporting under the new regulations, with some slated to start as early as the beginning of 2026, CARB has recently indicated that it will exercise enforcement discretion for the early cycles of reporting for the new laws.
The new laws will introduce climate-related reporting requirements for most large companies in the U.S., even as other climate disclosure regulations, such as the SEC’s climate reporting rule, appear increasingly less likely to be implemented. CARB recently issued a preliminary list of more than 4,000 U.S. companies likely to be required to comply with the new climate reporting laws.
The regulations, SB 253 and SB 261, were approved by Governor Newsom in 2023, and signed into law in October 2024. SB 253 requires companies with revenues greater than $1 billion that do business in California to report annually on their direct Scope 1 and 2 emissions, and Scope 3 value chain emissions, including those associated with supply chains, business travel, employee commuting, procurement, waste, and water usage. SB 261 applies to U.S. companies that do business in California and with revenues greater than $500 million to prepare a report disclosing their climate-related financial risk, as well as measures to reduce and adapt to that risk.
Disclosures of Scope 1 and 2 emissions under the new law is scheduled to begin in 2026, covering the previous fiscal year, while Scope 3 emissions reporting will begin in 2027, while the first climate-related risk reports are to be published by January 1, 2026.
Earlier this week, CARB also issued a new draft template in preparation for the commencement of reporting under SB 253, aimed at streamlining reporting of Scope 1 and 2 greenhouse gas emissions for companies under the new regulation. Use of the template by reporting companies is voluntary for the first reporting cycle in 2026. CARB added that it is seeking feedback on the template through October 27.
Click here to access the notice of the updated timeline, as well as the new template and public docket for feedback.
