California Climate Accountability Update: Highlights from CARB Workshop on SB 253 & SB 261

The California Air Resources Board (CARB) hosted a public workshop on May 29, 2025 to discuss the development of California’s Corporate Greenhouse Gas Reporting Program established by Senate Bill (SB) 253 and the Climate-Related Financial Risk Disclosure Program authorized by SB 261, collectively called the California Climate Accountability Package (CCAP).

Despite an ambiguous timeline for the release of full regulatory guidance, the original reporting deadlines established by CCAP remain intact, with the first deadline approaching on January 1, 2026. The regulation, which requires companies doing business in California to annually disclose scopes 1, 2, and 3 GHG emissions (SB 253) and to biennially report on climate-related financial risks (SB 261), introduces unprecedented climate-related disclosure requirements for U.S. companies. While CARB noted its intent to publish full regulatory guidance by the end of 2025, companies would benefit from beginning compliance work now to prepare for the January 2026 reporting deadline.

Key Takeaways from the May 2025 CARB Workshop

• Record Turnout: This workshop was the most widely attended ever hosted by CARB, demonstrating the public’s strong interest in the CCAP and desire for more detailed guidance.
• Guidance Delay: CARB previously announced that it would share regulatory guidance for SB 253 and SB 261 by July 1, 2025. Throughout the webinar, it became clear full regulatory guidance may not be ready by July 1, 2025. Instead, CARB emphasized that it plans to release full regulatory guidance “by the end of the year.”
• Reporting Deadlines Stand: Despite the ambiguous timeline for regulatory guidance, CARB reiterated that SB 253 and SB 261 reporting deadlines remain intact for now:
  • For SB 253, Scopes 1 and 2 greenhouse gas emissions are expected in 2026 on calendar year 2025 data, and Scope 3 greenhouse gas emissions are expected in 2027 on calendar year 2026 data.
  • For SB 261, a climate-related risk report aligned with the Taskforce on Climate-related Financial Disclosures (TCFD) and/or the International Sustainability Standards Board (ISSB) are expected to be published on company websites on or before January 1, 2026.
• Definitions Still Evolving: CARB provided working definitions for such terms as “doing business in California” and “revenue,” but has requested multiple rounds of public feedback throughout 2025 before complete regulatory guidance is finalized.