If your company has been racing toward an August deadline to file its first greenhouse gas emissions report in California, you’ve been gifted three more months on the clock. On June 24, 2026, the California Air Resources Board (CARB) announced it intends to push the first-year reporting deadline under SB 253 from August 10, 2026 to November 10, 2026. Here’s what changed, what didn’t, and what your team should be doing right now.
What CARB announced:
The headline is a three-month deferral of the initial Scope 1 and Scope 2 reporting deadline under SB 253, the Climate Corporate Data Accountability Act. CARB paired that with a promise to make “limited changes” to the underlying regulation in order to clarify certain requirements.
On February 26, 2026, CARB’s board approved its Initial Regulation implementing SB 253 (and its companion law, SB 261). That regulation was submitted to the Office of Administrative Law (OAL) for final review. CARB has now withdrawn it from OAL to make targeted amendments, including the new proposed November 10 deadline, and will release those changes for a 15-day public comment period before resubmitting to OAL for final approval.
What this means in plain terms
This is just a timing adjustment. The core requirements are intact:
- Who’s covered: U.S.-based companies with more than $1 billion in total annual revenue that “do business in California.”
- What’s due in 2026: Scope 1 (direct emissions) and Scope 2 (emissions from purchased energy) for the prior fiscal year. Most entities will report fiscal year 2025 data; companies whose fiscal year ends on or before February 1, 2026 will report the year ending in 2026.
- What’s coming in 2027: Scope 3 (value-chain) emissions. CARB has a separate rulemaking underway to develop those rules, so Scope 3 remains in the pipeline.
Some welcome flexibility for year one
CARB has signaled meaningful leniency for this first cycle. Limited assurance (third-party verification) is not required for the 2026 report—though if a company already has assurance over its data, it should provide it. Companies that already disclose Scope 1 and Scope 2 emissions through a voluntary program or another regulatory regime can generally submit that same information, and use of CARB’s reporting template is optional.
Don’t forget the companion law—and the litigation
SB 253 isn’t the only regulation to watch. Its sibling, SB 261 (the Climate-Related Financial Risk Act), applies to companies with more than $500 million in revenue and requires a biennial climate-risk report. That law has been on a different track: in November 2025, the Ninth Circuit enjoined CARB from enforcing SB 261, and CARB has confirmed it won’t penalize companies that missed the January 1, 2026 statutory deadline while the injunction stands.
The injunction stems from a First Amendment challenge brought by the U.S. Chamber of Commerce and allied business groups (Chamber of Commerce v. Sanchez), arguing the laws compel speech on a contested policy issue. Notably, the Ninth Circuit paused SB 261 but let SB 253 proceed. Oral arguments were heard on January 9, 2026, and a decision is still pending—so the legal backdrop remains fluid even as SB 253 compliance moves forward.
What to do now
The extra runway is a gift for stress-testing your data. A few practical priorities:
- Confirm whether you’re in scope. Run the $1 billion revenue and “doing business in California” tests, and remember that a parent’s consolidated report can cover in-scope subsidiaries (though fees are assessed per entity).
- Lock down your Scope 1 and 2 inventory. Use the months you just gained to tighten data quality and methodology rather than scrambling at the deadline.
- Watch the 15-day comment period. The clarifying amendments may answer open questions—and the November date won’t be final until OAL signs off.
- Keep building toward Scope 3. The 2027 obligation is still coming, and the data work takes time.
- Track the Ninth Circuit. A ruling could reshape the enforcement landscape for both laws.
Three extra months is a relief, but the direction of travel is unchanged: California’s climate disclosure regime is moving forward, and the companies that treat this deferral as preparation time will be the ones ready when reports come due