Which companies are impacted by SB 253?
California SB 253, also known as the Climate Corporate Data Accountability Act, was signed into law in October 2023. California’s climate disclosure laws under SB 253 apply to a broad range of business entities operating in the state.
A company is subject to SB 253 if it meets all of the following criteria:
- It is a US-based business entity formed as a corporation, partnership, limited liability company, or other business entity
- It does business in California
- It has total annual revenues exceeding $1 billion
This revenue threshold means California SB 253 impacts over 5,400 organizations annually, spanning industries from technology and finance to retail and manufacturing. The law applies regardless of where a company is headquartered; what matters is that the business entity does business in California and crosses the annual revenue threshold.
Companies already familiar with SB 261, California’s companion climate law requiring climate-related financial risk disclosures, should note that SB 253 and SB 261 work in tandem as part of California’s broader push for corporate climate accountability.
What are the key requirements?
California SB 253 requires annual greenhouse gas emissions reporting across all three emissions scopes. The reporting standards align with greenhouse gas protocol standards, ensuring companies produce standardized, comparable emissions data.
Scope 1 and Scope 2 emissions (due November 10, 2026)
- Scope 1 covers direct greenhouse gas emissions from sources owned or controlled by the reporting entity
- Scope 2 covers indirect emissions from purchased electricity, heat, or steam
- These must be reported using global greenhouse gas accounting methodologies consistent with the GHG Protocol
- CARB will require independent verification of emissions data, meaning companies must engage assurance providers to validate their disclosures
Scope 3 emissions (beginning 2027)
- Scope 3 emissions reporting begins in 2027, 180 days after Scope 1 and 2 disclosures are due
- Scope 3 includes downstream greenhouse gas emissions and indirect emissions across the value chain, such as business travel, employee commutes, and supply chain activity
- Scope 3 emissions often account for over 90% of an organization’s climate impact
- Good faith efforts protect against penalties for scope 3 misstatements through 2030; penalties for noncompliance apply only for nonfiling until that date
Penalties and enforcement
CARB can impose administrative penalties up to $500,000 per year for noncompliance. However, no penalties will be imposed for 2026 reporting if good faith efforts are demonstrated. Companies must also pay an annual fee to support the corporate greenhouse gas reporting program’s administration.
All disclosures must be publicly disclosed, increasing scrutiny from investors, regulators, and other stakeholders interested in corporate carbon emissions and climate risk management.
What can you do to prepare before the deadline?
The three-month extension is a welcome window, but November 10, 2026 is approaching quickly. Here is how to use the additional time effectively.
Assess your data readiness
- Conduct an internal audit of your Scope 1 and Scope 2 emissions data sources
- Identify gaps in your emissions data and begin collecting industry average data where direct measurement is unavailable
- Ensure your data management systems can produce assurance ready reports
Engage an assurance provider early
- CARB is tasked with developing assurance standards for emissions reporting, and third party assurance will be required
- Engaging multiple assurance providers for initial discussions can help you understand the limited assurance process and timelines
- Starting early helps ensure the assurance process minimizes disruption to your operations
Monitor CARB guidance closely
- Subscribe to CARB updates at the program regulation webpage or via govDelivery to receive notice of the 15-day public comment period
- Review CARB-released resources on the Corporate GHG Reporting Program to align your internal processes with final requirements
- For questions, contact CARB directly at climatedisclosure@arb.ca.gov
Build toward Scope 3 readiness
- Even though Scope 3 emissions reporting does not begin until 2027, now is the time to begin mapping your value chain
- Engage your suppliers and partners early to understand where emissions data will need to be gathered