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As discussed at the August 21, 2025, workshop, the California Air Resources Board (CARB) is seeking public comment on a draft reporting template for Scope 1 and Scope 2 greenhouse gas (GHG) emissions. CARB is also seeking public comment on a memo containing guidance on using the template under the Corporate Greenhouse Gas Reporting Program authorized by Senate Bill (SB) 253 (Wiener, Stats. 2023, Ch. 382; Health & Saf. Code § 38532), as amended by SB 219 (Wiener, 2024, Ch. 766; Health & Saf. Code § 38532).
Draft Template
We invite stakeholders to review the draft template and provide feedback on its structure, substance, and alignment with SB 253’s overarching objectives. Stakeholders may submit comments to CARB’s public docket, which will remain open through October 27, 2025.
This draft template is intended to provide guidance that entities may choose to follow on submitting data in compliance with the Scope 1 and Scope 2 emissions reporting requirement in 2026 for reporting entities subject to SB 253. Use of this template is voluntary for the 2026 reporting cycle. CARB will provide guidance on later reporting cycles as part of its regulatory process. CARB is seeking input on this draft template to help CARB further refine the template.
Memo
To help staff develop more comprehensive and accessible reporting guidance, CARB is seeking stakeholder feedback particularly on the topics highlighted in the memo accompanying the template.
For additional information, please visit the California Corporate Greenhouse Gas (GHG) Reporting and Climate Related Financial Risk Disclosure Programs webpage and CARB’s Resources. 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 SB 253 is being developed by 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, subject to the CARB Enforcement Notice issued in December 2024; emissions disclosures in 2027 and later must also include Scope 3 emissions.
The Climate Related Financial Risk Disclosure Program authorized by SB 261 (Stern, Stats. 2023, Ch. 383; Health & Saf. Code § 38533) also applies to both public and private U.S. companies that do business in California with total annual revenues in excess 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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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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