The California Air Resources Board (CARB) released a list of more than 4,000 companies that will be required to comply with the state’s new climate reporting laws, mandating disclosures on climate-related risks and opportunities, and for some companies on value chain greenhouse gas emissions as well.
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. In total, the CARB list includes 4,160 U.S. companies, including the majority of S&P 500 constituents.
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.
Of the companies included in CARB’s new list, around 60% (2,503) are based outside of California. Most companies listed (2,596) will be required to comply with both SB 253 and SB 256, while 1,564 will be subject only to SB 261.
CARB noted that the list is preliminary, and may not include all companies covered by the new climate-related reporting laws, as it is based on data from March 2022, noting that it is a company’s responsibility to report under the regulations even if not included on the list. The list also may include comes companies that will not be required to report under the regulations, based on recently released exemptions, such as subsidiary companies if their parent company issues a report on their behalf.
Click here to access CARB’s list.
