CARB adopts Initial Regulation for SB 253/SB 261 climate disclosure requirements

The California Air Resources Board approved the California Greenhouse Gas Reporting and Climate Financial Risk Disclosure Initial Regulation implementing Senate Bills 253 and 261 (as amended by SB 219). The regulation establishes the administration and implementation fees for the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). Key requirements include an August 10, 2026 initial reporting deadline for Scope 1 and Scope 2 emissions under SB 253, with Scope 3 reporting deferred to later years. Annual flat fees will be implemented with fee notices issued by September 10 each year starting in 2026. Entity thresholds are U.S. entities with over $1 billion annual revenue (SB 253) and over $500 million (SB 261) doing business in California. Tax-exempt nonprofits, government entities, and insurance companies are exempt. CARB will use enforcement discretion for good-faith first-year submissions. SB 261 enforcement is currently stayed pending Ninth Circuit litigation.