California Air Resources Board Hosts Second Workshop on California Corporate Greenhouse Gas Reporting Program

On July 21, 2026, the California Air Resources Board (CARB) hosted a virtual public workshop with stakeholders to support the development of California’s corporate greenhouse gas (GHG) emissions reporting program established by the Climate Corporate Data Accountability Act (SB 2531), as amended by SB 2192 (see Deloitte’s December 4, 2025 [updated July 1, 2026], Sustainability Spotlight for more information about SB 219). The objectives of the workshop were to (1) provide an update on the initial regulations approved by CARB on February 26, 2026; (2) provide an update on the regulatory concepts for Scope 1 and Scope 2 GHG emissions reporting requirements in 2027 and beyond; (3) discuss the proposed approach for Scope 3 emissions reporting starting in 2027; and (4) present 2027 assurance requirements and standards. During the workshop, CARB outlined these key staff concepts, which are publicly available and summarized below, and solicited feedback on certain staff concepts presented.

As announced on June 24, 2026, and during the workshop, the initial regulation has been withdrawn to (1) defer the 2026 reporting deadline to November 10, 2026, and (2) make limited clarifying changes.3 CARB stated that the deferred November 10 deadline proposed for 2026 would apply to future years as well. Entities would need to disclose their required GHG emissions for Scope 1, Scope 2, and Scope 3 for the preceding year by November 10.

CARB indicated that, starting in 2027, entities regulated by the California Department of Insurance (CDI) may submit the same report to meet both CDI and SB 253 requirements, provided that the CDI report addresses all CARB requirements. CARB stated that the current CDI reporting requirements may not entirely satisfy CARB’s requirements; thus, supplemental information could potentially be required in these entities’ SB 253 reports.

CARB gave an overview of the proposed regulatory concepts for reporting in 2027 and annually thereafter, focusing on its intent to align with the current GHG Protocol4 whenever possible and provide the necessary clarifications to be consistent with existing California regulations.

In line with the GHG Protocol, entities would be required to disclose gross emissions from each scope (Scope 1, Scope 2, and Scope 3). The following disclosures would also be required:

• Quantification methods, including:
  • Consolidation approach.
  • Any tools or models used as part of the quantification method.
  • Global warming potential (GWP) values used.
  • Emissions factor sources.
• Information about measurement uncertainty and missing or substituted data.
• Biogenic emissions.

CARB also provided additional clarifications related to GHG reporting, including:

• A base year will be established for reporting under SB 253.
• A recalculation threshold of 5 percent will be required.
• Entities may report, in a separate section, investments in emissions reductions or removals and other supplemental information.

At a previous stakeholder workshop, CARB proposed three options for reporting Scope 3 emissions. CARB has decided to propose the “category phase-in” option, under which entities would report on the five most reported Scope 3 categories, as determined by CARB, beginning in 2027, with phase-in of other categories occurring in a to-be-determined future year. The initial required Scope 3 categories would be:

• Category 1 (purchased goods and services).
• Category 3 (fuel and energy-related activities).
• Category 5 (waste generated during operations).
• Category 6 (business travel).
• Category 7 (employee commuting).

Entities may voluntarily report the other Scope 3 categories, and an entity would be permitted to exclude data related to the five required categories if it believes such data to be immaterial.

To support initial implementation of SB 253 in 2026 for prior-year emissions, CARB has issued an enforcement notice indicating that it will exercise discretion for an entity’s first reports issued in 2026, and such reports may be submitted regardless of whether limited assurance has been obtained for the data (see CARB’s November 2025 FAQ document for more information). CARB did clarify during the workshop that reporting biogenic emissions would be subject to limited assurance. CARB staff retained the list of proposed assurance standards5 previously shared and is requesting feedback on these standards. During the workshop, CARB highlighted that each of the proposed assurance standards features different accountability mechanisms. Accordingly, CARB proposed that assurance engagements be performed in full conformance with one of the proposed assurance standards. Requirements to which such entities would be subject would include, but would not be limited to, engagement scope, method used, provider qualifications, evidence gathering, independence, oversight mechanism, and reporting.

CARB announced that industry-focused listening sessions on SB 253 will be held in August and September 2026. Stakeholders are encouraged to continue providing feedback on proposals and may do so by submitting written comments by e-mail to climatedisclosure@arb.ca.gov.

CARB plans to share additional materials by September 1, 2026, to support 2026 reporting. These materials will include an informational document and video with instructions for using the voluntary online intake platform for fee assessment and GHG emissions reporting.

For more information on the virtual workshop, see CARB’s Web site.