California Corporate Greenhouse Gas Reporting: Notice of Upcoming Rulemaking Update to Further Clarify Requirements and Deferring 2026 Reporting Deadline

Overview

The California Air Resources Board (CARB) is updating its regulatory proposal to defer the reporting deadline for entities to report Scope 1 and Scope 2 greenhouse gas (GHG) emissions from August 10, 2026, to November 10, 2026. This three-month deferral will give reporting entities additional time following the formal adoption of Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation, if approved by the Office of Administrative Law (OAL), at Title 17, California Code of Regulations (CCR), Article 6, sections 96070-96077 (the “Initial Regulation”).

In addition, CARB will be proposing limited changes to the regulation to clarify certain requirements and will make these available for comment as part of a forthcoming 15-day public comment period.

Because this step may delay finalizing this regulatory package, as noted above CARB will propose, as part of this 15-day change, a three-month deferral in the reporting deadline. A new proposed reporting deadline of November 10 will help ensure reporting entities have additional clarity following approval of the final regulation before reporting is due.

Rulemaking Background

On February 26, 2026, the Board approved the Initial Regulation, which establishes a fee component and sets the first-year reporting deadline under Health and Safety Code (HSC) § 38532. The Initial Regulation and associated rulemaking documents submitted to OAL for final review and approval have been withdrawn by CARB to allow more time to make limited changes to clarify certain requirements. CARB will make these available for comment during a 15-day public comment period and will subsequently resubmit the regulation to OAL. Notice of this 15-day public comment period will be forthcoming. To view rulemaking documents, visit the program regulation webpage.

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ESG Administration provides companies required to report under SB 253 with the resources and expertise to meet CARB's requirements, focusing on minimizing the internal burden on your team. To learn more about ESG Administration, contact Joe Holman at joe.holman@esgadmin.com

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