CARB Releases Preliminary List of Reporting-Covered Entities

As announced at its public workshop on August 21, 2025, the California Air Resources Board (CARB) has released a preliminary listing of reporting/covered entities that may be subject to the Corporate Greenhouse Gas Disclosure Program (Senate Bill [SB] 253) and the Climate-Related Financial Risk Disclosure Program (SB 261), respectively, to support development of the fee regulations. This list is preliminary and should not be solely relied upon for determining applicability of the reporting requirements under the senate bills.

In preparing this preliminary listing, CARB used the definitions proposed at its August 21 workshop for “revenue” and “doing business in California.” (See our August 26, 2025, news item for more information about these proposed definitions.) Entities should consider the following when reviewing this preliminary listing:

• CARB used California Secretary of State registered business data as of March 2022 in determining entities that are “doing business in California.”
• CARB did not provide additional information about how revenue was determined in preparing this preliminary listing other than that the determination is in line with the definition proposed at the August workshop and that a proprietary dataset was used.
• This preliminary listing does not reflect the proposed exemptions discussed at the August workshop.
• “Each potentially-regulated entity remains responsible for compliance with statutory requirements, regardless of whether it was included in staff’s preliminary listing or outreach.”1

In addition, CARB has opened a voluntary public survey in which stakeholders can provide feedback on the preliminary listing. CARB indicates that the survey’s purpose is help entities assess “whether they are potentially subject to the reporting programs, as well as to help improve CARB's data accuracy.” CARB did not provide a deadline for survey responses.