California sets out how to file first climate reports
The California Air Resources Board (CARB) published guidance on 1 September for entities preparing their first Scope 1 and Scope 2 greenhouse gas (GHG) emissions reports under Senate Bill (SB) 253, ahead of a 10 November 2026 deadline.
Under enforcement discretion first signalled in December 2024, entities may submit whatever Scope 1 and Scope 2 data they already had or were collecting at that point, assured or not, and limited assurance will not be enforced this cycle. Companies that were not collecting data as of 5 December 2024 are asked instead to submit a statement of non-reporting on company letterhead. CARB has also opened a voluntary intake platform for contact details, fee billing and, optionally, the emissions reports themselves.
Acceptable formats are equally flexible: an existing annual report, data already reported to another programme, CARB’s own draft template, or an email to the climate disclosure inbox. Entities are encouraged, but not required, to supply methodologies, emission factors, organisational boundaries and disaggregated data.
CARB’s second rulemaking, covering 2027 onwards, will set reporting formats among other things, making this the moment to bring more order and comparability into the reporting process.
Read the guidance here.
