The California Air Resources Board (CARB) held a virtual public workshop on May 29th to support the development of California’s Corporate Greenhouse Gas Reporting Program (established by Senate Bill 253) and the Climate-Related Financial Risk Disclosure Program (established by Senate Bill 261). CARB included an overview of the SB 253, SB 261, and SB 219, which extended certain deadlines and administrative changes, updates on timing and scoping for the regulations, as well as feedback and next steps for companies exposed.
Before addressing and reviewing the main highlights of the workshop, let’s run through a quick refresher of California’s climate disclosure legislation:
- The Climate Corporate Data Accountability Act (SB 253, passed in 2023) mandates that businesses with annual revenues exceeding $1 billion and operating in California disclose their greenhouse gas (GHG) emissions. Starting in 2026, companies must report fiscal year 2025 Scope 1 and Scope 2 emissions, with Scope 3 emissions reporting beginning in 2027. The law requires third-party verification of these disclosures and aims to enhance transparency and accountability in corporate climate practices.
- The Climate-Related Financial Risk Act (SB 261, passed in 2023) mandates businesses with annual revenues exceeding $500 million and operating in California disclose climate-related financial risks and their mitigation strategies. Starting in 2026, companies must submit biennial reports detailing physical and transition risks due to climate change, as well as measures taken to adapt. These reports must align with the Task Force on Climate-Related Financial Disclosures (TCFD) framework and be publicly accessible.
- California Senate Bill 219 (SB 219, passed in 2024) was put into place to consolidate and amend the state's climate disclosure laws (SB 253 and SB 261). It extended the deadline for CARB to finalize regulations to July 1, 2025, while maintaining the original reporting deadlines. SB 219 mandates companies exceeding $500 million in annual revenue operating in California disclose greenhouse gas emissions (Scopes 1, 2, and 3) and climate-related financial risks. It also introduces flexibility for CARB to set reporting schedules and eliminates filing fees, aiming to streamline compliance while ensuring transparency in corporate climate accountability.
Businesses must stay prepared for disclosures related to both SB 253 and SB261. While CARB will exercise enforcement discretion for the first reporting cycle assuming entities demonstrate good faith efforts to comply with the requirements of the law, companies that fall within the scope of California’s climate legislation must stay tuned to requirements and ensure compliance.
Download our summary guide below outlining critical deadlines and timing to look out for covered during CARB’s May 29th workshop.