California SB 253: Deadline Tracker
First Scope 1+2 report due August 10, 2026. Scope 3 starts 2027. Here's exactly what's required, who's in scope, and what CARB is enforcing.
Updated: March 2026Sources: CARB regulations (Feb 26, 2026), PwC, BDO, Baker Tilly
Next Deadline
August 10, 2026
Scope 1 + Scope 2 emissions report due to CARB
Court challenge active: The Ninth Circuit heard oral arguments on January 9, 2026. The SB 261 injunction remains in effect, but SB 253 is unaffected — the August 10 deadline stands. CARB approved final regulations on February 26, 2026, pending OAL review.
Who's In Scope
| Law | Revenue Threshold | Who | First Report | Status |
|---|
| SB 253 | $1B+ annual revenue | US entities doing business in CA | Aug 10, 2026 | Active — deadline firm |
| SB 261 | $500M+ annual revenue | US entities doing business in CA | TBD (was Jan 1, 2026) | Injunction — not enforced |
Key definitions from CARB's February 2026 regulations
"Revenue" means gross receipts as defined in California Revenue and Taxation Code Section 25120(f)(2). This is broader than GAAP revenue — it includes interest, dividends, and property sale proceeds.
"Doing business in California" means actively engaging in any transaction for financial gain or profit in California. Entities whose only California presence is teleworking employees are exempt.
Both subsidiaries and parent companies must independently assess their obligations. A parent company can file a consolidated report covering all in-scope subsidiaries.
Exemptions
Tax-exempt nonprofits and charities. Federal, state, and local government entities. Entities majority-owned (over 50%) by government. Entities whose only California activity is wholesale electricity transactions. Certain insurance companies (CARB is reviewing this exemption).
Full Timeline
Oct 2023
Governor Newsom signs SB 253 and SB 261 into law.
Dec 2024
CARB issues enforcement notice: no penalties for good-faith first-year submissions under SB 253.
Nov 2025
Ninth Circuit grants injunction on SB 261. SB 253 remains unaffected.
Dec 2025
CARB posts proposed SB 253 regulations with August 10, 2026 deadline. 45-day public comment period opens.
Jan 2026
Ninth Circuit hears oral arguments on SB 253 and SB 261 legal challenge. No ruling yet.
Feb 26, 2026
CARB unanimously approves initial SB 253/SB 261 regulations. Pending OAL review.
Aug 10, 2026
SB 253 Scope 1+2 deadline. First reports due to CARB. Covers FY 2025 data (or FY 2026 if fiscal year ends before Feb 1).
Sep 10, 2026
CARB issues annual fee determination notices to in-scope entities. Payment due within 60 days.
2027
Scope 3 emissions reporting begins (FY 2026 data). Safe harbor provision protects good-faith Scope 3 disclosures through 2030.
2030
Scope 1+2 requires reasonable assurance (up from limited). Scope 3 requires limited assurance. Safe harbor expires.
What to Report in 2026
Required
Scope 1 and Scope 2 GHG emissions for the applicable reporting year. Reports must follow the GHG Protocol. Reports will be submitted to a CARB-designated reporting organization and made publicly accessible on a digital platform.
Reporting period
If your fiscal year ends on or before February 1, 2026: report FY 2026 data. If your fiscal year ends after February 1, 2026: report FY 2025 data. You may also choose to report the most recent preceding fiscal year if that data is available.
Not required in 2026
Scope 3 emissions (starts 2027). Third-party assurance (enforcement discretion for first year). Use of CARB's reporting template (optional in 2026).
Enforcement Discretion: What It Means
CARB has stated it will not issue penalties in 2026 for companies acting in good faith. Specifically:
Companies that were not collecting emissions data at the time of CARB's December 2024 enforcement notice may submit a statement to CARB's public docket explaining why they did not file a report, instead of filing actual emissions data.
Companies that were collecting data should submit what they have. CARB has indicated it may provide relief on a case-by-case basis for companies that request it.
What "good faith" means in practice: You don't need perfect data. You need to show you tried. A reasonable Scope 1+2 inventory using the GHG Protocol, with documented methodology and emission factor sources, meets the good-faith standard. Starting now gives you 5 months to build that inventory.
Penalties for non-compliance after the first year: up to $500,000 per entity per reporting year. The safe harbor for Scope 3 (good-faith misstatements not penalized) runs through 2030.
SB 261: Current Status
SB 261 requires biennial climate-related financial risk reports from companies with $500M+ revenue doing business in California. The January 1, 2026 deadline has been paused by the Ninth Circuit injunction. CARB has stated it will not enforce SB 261 until the appeal is resolved.
Companies may voluntarily submit SB 261 reports through CARB's public docket (open December 1, 2025 through July 1, 2026). The court could rule at any time — companies should be prepared to publish reports promptly if the injunction is lifted.
Preparation Checklist: What to Do Before August 10
Confirm scope: Does your entity meet the $1B revenue threshold and "doing business in CA" definition?
Determine reporting period: FY 2025 or FY 2026 based on your fiscal year-end date.
Collect Scope 1 activity data: fuel purchases, fleet fuel cards, refrigerant maintenance logs.
Collect Scope 2 activity data: utility bills (kWh) for all facilities. Request 12-month summaries from providers.
Select emission factors: EPA GHG EF Hub 2024 for combustion, eGRID 2024 for electricity, IPCC AR6 for refrigerants.
Calculate emissions: Activity data x EF / 1,000 = tCO2e per source. Sum by scope.
Document methodology: Which EFs used, which reporting boundaries, any assumptions or estimates.
Internal review: Have a second person check the data. Reconcile fuel costs with accounts payable.
Prepare for Scope 3 (2027): Begin mapping your top suppliers by spend and requesting emissions data.
Monitor CARB: Watch for the final reporting platform and submission mechanics. OAL review pending.
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