California Pushes Back Deadline for First Corporate Climate Reports to November

The California Air Resources Board (CARB), the regulator charged with developing and enforcing the state’s new corporate climate reporting regulations, released a new notification indicating that it plans to delay the deadline for companies’ first mandatory emissions disclosures to November 10, from the current August deadline.

According to CARB, the delayed deadline is aimed at giving companies more time, as the regulator plans to introduce limited changes to the climate reporting regulation, which may delay its final approval.

California’s new climate reporting regulations, SB 253 and SB 261, were signed into law in October 2024. SB 253 requires companies with revenues greater than $1 billion that do business in California to report annually on their direct Scope 1 and 2 emissions, and Scope 3 value chain emissions, including those associated with supply chains, business travel, employee commuting, procurement, waste, and water usage. SB 261 applies to U.S. companies that do business in California and with revenues greater than $500 million to prepare a report disclosing their climate-related financial risk, as well as measures to reduce and adapt to that risk.

The new laws will introduce climate-related reporting requirements for most large companies in the U.S. CARB recently issued a preliminary list of more than 4,000 U.S. companies likely to be required to comply with the new climate reporting laws.

Notably, the regulations are still facing legal challenges, with the U.S. Ninth Circuit appeals court issuing an injunction late last year to pause the implementation of SB 261 pending the outcome of an appeal.

CARB approved the adoption of the regulations earlier this year, and set a deadline of August 10, 2026 for initial reporting of corporate greenhouse gas (GHG) emissions. While SB 253 requires disclosure of value chain emissions, in its first year of application, reporting requirements under the new regulation only include Scope 1 and 2 emissions, with Scope 3 reporting only mandated from 2027.

CARB subsequently submitted the regulations for final approval by the California Office of Administrative Law (OAL), but has since withdrawn the submission to make limited changes, which is said it will make available for comment as part of a 15-day public comment period, and then resubmitted to OAL. The regulator said that the new step may delay finalization of the regulation, leading to the need for a later deadline.

CARB said:

“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.”