CA SB 253: CARB Releases 2026 Reporting Guidance and Voluntary Intake Platform Ahead of November Deadline

The California Air Resources Board (CARB) has released its guidance for the first reporting cycle under California’s Climate Corporate Data Accountability Act (SB 253). The November 10 deadline reflects CARB’s earlier deferral of the inaugural reporting date from August 10, 2026.

What's in the new guidance

• A formal guidance document. CARB addresses how reporting entities can prepare and submit their initial 2026 Scope 1 and Scope 2 emissions disclosures under SB 253.
• A voluntary online intake platform. Companies may now use the platform to provide contact information, submit a Scope 1 and Scope 2 report, or provide a statement of non-reporting. Use of the platform is optional for the 2026 reporting cycle, and CARB will also allow submissions through its climate-disclosure email inbox.
• A platform tutorial. CARB has released an instructional video to help reporting teams navigate the intake platform.
• Continued first-year enforcement discretion. For the 2026 cycle, CARB will accept Scope 1 and Scope 2 disclosures whether the data has received limited assurance or not. CARB requests that in-scope companies meeting the criteria outlined in the December 2024 Enforcement Notice electing to not report Scope 1 & 2 data submit a statement of non-reporting on company letterhead.

What companies should focus on now

CARB’s release does not change who is in scope or add substantive requirements for the 2026 reporting cycle. It does, however, give companies clearer direction on how to prepare and submit their Scope 1 and Scope 2 information ahead of the November 10 deadline. Here are some key steps to take now:

• Review CARB’s 2026 reporting guidance, intake platform, and reporting-format options before deciding how to submit 2026 information.
• Confirm that Scope 1 and Scope 2 data are report-ready. Consider including the underlying methodology, organizational boundary, data sources, and emissions factors used (optional for 2026).
• Consider the appropriate reporting format. CARB reporting formats include an existing annual report, information previously reported through another program or voluntary initiative, or CARB’s Scope 1 and Scope 2 reporting template.
• If the company was not collecting and was not planning to collect Scope 1 and Scope 2 information as of December 5, 2024, prepare a statement of non-reporting on company letterhead and submit it by the November 10 deadline.
• Keep Scope 3 planning moving in parallel. CARB is developing Scope 3 requirements for 2027 and beyond through a second rulemaking process, and key implementation details remain under development.

CARB’s Initial Regulation is still subject to Office of Administrative Law approval as of September 1, 2026, and SB 253 remains subject to ongoing litigation. Companies should continue to monitor both developments, but CARB’s current guidance identifies November 10, 2026 as the deadline for the first Scope 1 and Scope 2 reporting cycle.

We will continue tracking CARB’s rulemaking and implementation process and will share updates as the regulatory package advances.

If we can be helpful as you consider how these insights will affect your business, please don’t hesitate to reach out to our team.

Contact us:

Abbe Billings, Partner, Third Economy
abbe.billings@thirdeconomy.com

Disclaimer: This update reflects publicly available information as of September 2026. The information provided does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available are for general informational purposes only.