California Pushes Back Initial Rulemaking for Landmark Climate Reporting Laws
The California Air Resources Board (CARB) has announced a delay in the initial rulemaking process for new regulations requiring large companies to disclose value chain emissions and report on climate-related financial risks. The initial rulemaking, previously expected in October 2025, is now slated for presentation in the first quarter of 2026.
According to a CARB notice, the delay stems from the significant volume of public comments received on recently released resources pertaining to the regulations, as well as “ongoing input related to identifying the range of covered entities.”
Despite the delay in rulemaking, CARB has indicated that the overall reporting timelines remain unchanged, with some reporting requirements still scheduled to begin in early 2026. Though, the board also stated it will exercise enforcement discretion during the initial reporting cycles.
These new laws, SB 253 and SB 261, were approved by Governor Newsom in 2023 and signed into law in October 2024. SB 253 mandates annual reporting on Scope 1 and 2 emissions, as well as Scope 3 value chain emissions (including supply chains, business travel, employee commuting, procurement, waste, and water usage) for companies with revenues exceeding $1 billion that do business in California. SB 261 requires U.S. companies with revenues greater than $500 million doing business in California to disclose climate-related financial risks and outline measures for risk reduction and adaptation.
Reporting of Scope 1 and 2 emissions is scheduled to begin in 2026, covering the prior fiscal year, while Scope 3 emissions reporting will follow in 2027. The first climate-related risk reports are due January 1, 2026.
CARB recently released a preliminary list identifying over 4,000 U.S. companies likely to be subject to the new reporting requirements. The board also issued a draft template this week to help streamline the reporting of Scope 1 and 2 greenhouse gas emissions under SB 253. While use of the template is voluntary for the first reporting cycle in 2026, CARB is currently soliciting feedback on the template until October 27th.
This development occurs as other climate disclosure regulations, such as the SEC’s climate reporting rule, face legal challenges and appear less certain to be implemented.
More information, including the updated timeline notice, the new template, and the public docket for feedback, can be found at: https://ww2.arb.ca.gov/our-work/programs/corporate-ghg-reporting/resources.
