Regulatory roundup: California Corporate GHG Reporting update

The California Air Resources Board (CARB) is updating its California Corporate Greenhouse Gas Reporting regulations under Senate Bill (SB) 253 and plans to extend the deadline for reporting 2026 scope 1 and scope 2 greenhouse gas (GHG) emissions from August 10, 2026 to November 10, 2026.

The three-month extension is intended to provide reporting entities with additional time following final approval of CARB’s initial regulations by the Office of Administrative Law (OAL). CARB has withdrawn the previously submitted regulatory package to incorporate limited clarifications to certain requirements and will issue these changes for public comment through a forthcoming 15-day comment period before resubmitting the regulations for approval.

The updated timeline provides additional time for companies to prepare; however, organizations subject to SB 253 should continue advancing their GHG reporting efforts. The proposed changes are focused on clarifying regulatory requirements rather than changing the overall reporting obligation. Organizations subject to SB 253 should continue advancing their GHG inventory processes, data collection efforts, and internal controls to support timely and accurate reporting.

Given that CARB’s regulatory updates are still underway, companies can take a no-regrets approach by focusing on activities that will remain valuable regardless of final regulatory timing:

• Confirm reporting applicability and organizational boundaries to determine whether SB 253 applies and identify required reporting entities
• Advance scope 1 and scope 2 inventory development using established GHG Protocol accounting methodologies
• Strengthen data collection processes for activity data, emission factors, and supporting documentation
• Document inventory methodologies and controls to improve transparency and future assurance requirements
• Identify data gaps and improvement opportunities, particularly for areas that may require additional review or verification support
• Engage internal stakeholders early across sustainability, finance, operations, facilities, and procurement teams

The additional time provided by the proposed extension can help companies refine their reporting processes and address remaining data or governance gaps. However, organizations should avoid delaying preparation efforts, as robust GHG reporting programs require time to establish reliable data systems, documentation, and internal review procedures.

CARB’s final regulations and updated reporting requirements are expected following completion of the rulemaking process. Companies should continue monitoring CARB updates while progressing with practical readiness activities that will support compliance under the final adopted requirements.