California Air Resources Board Hosts Workshop to Discuss Corporate Greenhouse Gas Disclosures

On May 29, 2025, the California Air Resources Board (CARB) hosted a virtual public workshop with stakeholders “to support development of California’s Corporate Greenhouse Gas Reporting Program” established by the Climate Corporate Data Accountability Act (SB 253) and Climate‐Related Financial Risk Act (SB 261), as amended by SB 219. The objectives of the workshop were to provide information about compliance timing, suggest initial proposals on certain scope-related concerns raised by stakeholders, and solicit feedback.

Both CARB staff and Senator Weiner, the author of SB 253, stated that the compliance dates remain unchanged, notwithstanding the status of implementing the regulations. SB 253 requires disclosure of scope 1 and scope 2 greenhouse gas emissions starting in 2026 (on the basis of 2025 emissions, with limited assurance), and additional disclosure of scope 3 greenhouse gas emissions starts in 2027 (on the basis of 2026 emissions). SB 261 requires that a climate-related financial risk report be provided by January 1, 2026. During the workshop, CARB staff members reiterated that they will not take enforcement action regarding SB 253 for the first reporting cycle if an entity makes a good-faith effort to provide relevant emissions data, as described by CARB in its December 5, 2024, enforcement notice.

While SB 253, as amended by SB 219, includes a deadline of July 1, 2025, for implementing regulations, CARB’s staff suggested that it will work toward developing regulations by the end of the year. However, state law provides up to a year to finalize regulations once they are proposed. Although CARB is not required to issue regulations related to implementing SB 261, CARB has requested feedback on whether it should release regulations or guidance.

CARB noted that many stakeholders have requested guidance on the definition of doing business in California, revenue, and how to determine corporate relationships (identification of parent company). CARB provided initial staff concepts related to using existing regulations to address these interpretive issues. For example, Section 23101 of California’s Revenue and Tax Code (RTC), with minor modifications, could apply to the definition of doing business in California, revenue could be addressed by using the gross receipt concepts under RTC Section 25120(f)(2), and corporate relationships could be interpreted by using definitions similar to those used in the cap-and-trade program. After providing these initial staff concepts, CARB solicited stakeholder feedback.

More workshops are expected. For more information on the first virtual workshop, see CARB’s Web site.