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 The Initial Regulation and associated rulemaking documents submitted to OAL for final review and approval have been withdrawn by CARB to allow more time to make limited changes to clarify certain requirements.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 as part of a 15-day public comment period and will subsequently re-submit the regulation to OAL. Notice of this 15-day public comment period will be forthcoming. To view rulemaking documents, visit the program regulation webpage.
CARB has released several resources to assist entities in preparing and submitting 2026 Scope 1 and Scope 2 GHG emissions reports.
This GHG emissions reporting is required by Senate Bill (SB) 253 (HSC § 38532), and CARB’s Initial Regulation (planned to go into effect once approved by OAL, at Title 17, CCR, Article 6, sections 96070-96077).
Contact
For additional assistance, please contact climatedisclosure@arb.ca.gov. To ensure you receive future communications related to the CARB’s Corporate GHG Reporting Program, please subscribe.
Program Background
The California Corporate Greenhouse Gas Reporting Program, established by SB 253 (Wiener 2023, codified in HSC § 38532), requires U.S.-based companies, 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, Scope 2 and Scope 3 emissions for the prior fiscal year. SB 253 requires that the initial (first-year) annual emissions disclosures in 2026 address Scope 1 and Scope 2 emissions, and in subsequent years (beginning in 2027) must include Scope 3 emissions.
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