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The California Air Resources Board (CARB) has released a preliminary list of reporting/covered entities under the Corporate Greenhouse Gas Reporting Program and the Climate-Related Financial Risk Disclosure Program, authorized by Senate Bills (SB) 253 and SB 261, as amended by SB 219 (Wiener, 2024; amending Health and Safety Code §§ 38532 and 38533). CARB has prepared this preliminary list of reporting/covered entities based on the statutory requirements of being US-based, meeting the annual revenue threshold of $500 million or more, and doing business in California, assessed using the draft conceptual definitions described at the August 21, 2025 workshop. To develop this preliminary list, CARB matched California Secretary of State (SoS) registered business data with a proprietary dataset.
Staff relied upon the SoS data as a master-list of entities doing business in California, as it is publicly available. However, the SoS dataset used in staff’s analysis includes only active filings through March 2022 and may be missing companies. Due to a lack of a universal unique ID to match entities across datasets, staff used a partial match of company name fields between the datasets. Note, this preliminary list does not reflect potential exemptions discussed at the August 21 workshop. For more details on staff's methodology for developing a preliminary estimate of covered entities, refer to the August 21 workshop slides. A video of the workshop is also available.
This preliminary list is intended to support development of the fee regulation. Each potentially-regulated entity remains responsible for compliance with statutory requirements, regardless of whether it was included in staff’s preliminary list or outreach. To help validate the information in CARB’s preliminary list of entities, CARB is seeking stakeholder feedback through the survey tool linked below. Entities that believe they may be subject to these requirements, or may qualify for an exemption, are encouraged to complete the survey. Completion of the survey is voluntary.
For additional information, please visit the California Corporate Greenhouse Gas (GHG) Reporting and Climate Related Financial Risk Disclosure Programs webpage and CARB’s FAQ. CARB continues to seek feedback on these programs, which can be submitted to climatedisclosure@arb.ca.gov.
Background
The California Corporate Greenhouse Gas Reporting Program, authorized by Senate Bill (SB) 253 (Wiener, 2023) is being developed by the California Air Resources Board (CARB) and will require business entities formed under the laws of California, the laws of any other state of the United States or the District of Columbia, or under an act of the Congress of the United States, with total annual revenues in excess of one billion dollars ($1,000,000,000) that do business in California (“reporting entities”) to annually disclose their scope 1, 2 and 3 emissions for the prior fiscal year. The initial annual emissions disclosures are required to address scope 1 and 2 emissions with third-party limited assurance requirements and in subsequent years must include scope 3 emissions. The Climate Related Financial Risk Disclosure Program authorized by SB 261 (Stern, 2023) also applies to both public and private U.S. companies that do business in California with annual revenues of $500 million. This program is also currently under development by CARB and will require companies to publish biennial climate-related financial risk reports. SB 219 introduced amendments to parts of SB 253 and SB 261, including adjustments to regulatory timelines, the timing for reporting scope 3 emissions, fee payments, and other provisions.
Real and Increasing Costs of Climate Change Impacts for Californians
The science behind climate change is irrefutable. With the increasing severity and frequency of drought, wildfire, extreme heat, and other impacts, Californians just have to look out their windows to know that climate change is real and rapidly getting worse. The impacts once thought decades away are happening now. Recent reports detail some of the impacts to the state:
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A 2024 national report ranked California the worst state for natural disasters fueled by a changing climate, with expected annual losses totaling more than $16 billion statewide.
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Home insurance is harder and more expensive to get. Seven of California’s largest property insurers, State Farm, Allstate, Farmers, USAA, Travelers, Nationwide and Chubb recently limited new homeowners policies in the Golden State — raising questions about the stability of the California home insurance market.
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During an 11-year period, exposure to wildfire smoke caused more than 50,000 deaths in California and more than $400 billion in economic impacts.
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During seven extreme heat events over the past decade, California experienced $7.7 billion in losses.
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