Following its August 2025 public workshop, the California Air Resources Board (CARB) has released several resources (available on its Corporate GHG Reporting Resources webpage) to guide implementation of the state’s landmark corporate climate disclosure laws—Senate Bills 253, 261, and 219, collectively known as the “SB 200s”
In a public notice issued this month, CARB announced that it is proposing an updated timeline to bring the initial rulemaking for SB 253 (including fee-related provisions) before the Board in the first quarter of 2026, instead of Q4 2025. The agency cited the large volume of public comments and continued input related to identifying the range of covered entities as key reasons for the adjustment.
New Draft Materials Released
CARB’s latest postings since its workshop on August 21, 2025 are available on its Corporate GHG Reporting Resources webpage, include three cornerstone documents:
- Climate Related Financial Risk Report Checklist (posted September 2, 2025):
A guidance tool for companies subject to SB 261, outlining the expected structure and core disclosure areas aligned with the Task Force on Climate-Related Financial Disclosures (TCFD) and IFRS S2 frameworks. The checklist clarifies that Scope 3 emissions and detailed quantitative metrics will not be required for the initial reporting cycle. - Preliminary List of Reporting/Covered Entities and Voluntary Survey Tool (posted September 24, 2025):
A preliminary draft list of companies believed to meet California’s revenue and “doing business” criteria under SB 253 and SB 261. It may not be a comprehensive or complete list; thus entities are encouraged to review and validate their inclusion or exclusion through an online survey to ensure accuracy before final rule adoption. - Draft Scope 1 and 2 GHG Reporting Template for Scope 1 and Scope 2 GHG Emissions (posted October 10, 2025):
A preliminary reporting format for SB 253 disclosures that includes sections for organizational information, third-party verification, emissions boundary, data by source or gas, methodologies used, and emission-reduction initiatives. The template will remain voluntary for 2026 as CARB refines requirements based on stakeholder input. Notably, the current draft suggests that reporting entities would need to submit verified Scope 1 and Scope 2 emissions by June 30, 2026, meaning limited assurance verification must be completed before that date. However, this timeline remains tentative, as CARB is still reviewing stakeholder concerns and evaluating the feasibility of the proposed verification schedule.
Comment Opportunities and Contact Information
CARB is accepting feedback on the Draft Scope 1 and 2 GHG Reporting Template through October 27, 2025, via its public docket. Comments regarding the Preliminary List of Covered Entities may be submitted through an online survey, and general inquiries can be directed to [email protected].
What the Timeline Shift Means
The updated Q1 2026 rulemaking schedule for SB 253 provides additional time to assess readiness, validate data systems, and align reporting practices with relevant standards. However, CARB has not changed the statutory effective dates of the underlying laws, meaning that 2026 remains the target year for initial filing (by January 1, 2026, for SB 261 Climate Related Financial Risk Report and by June 30, 2026 [tentatively], for SB 253 Scope 1 and 2 GHG Emissions Report).
Next Steps for Companies
With the SB 200s set to become the nation’s most comprehensive state-level climate disclosure mandate, CARB’s latest releases represent a decisive step toward defining California’s new era of corporate climate accountability. In preparation, companies subject to or potentially covered under these laws should begin preparing now (if not done already) to ensure readiness while CARB finalizes the rules. The key proactive steps to prepare for implementation include:
- Confirm Applicability:
Evaluate whether your organization qualifies as a “reporting entity” under SB 253 (based on total annual revenues exceeding $1 billion and doing business in California) and/or as a “covered entity” under SB 261 (with revenues over $500 million and California operations). Multinational and complex corporate structures should also assess how applicability applies across parent and subsidiary levels, given the current ambiguity around consolidated versus entity-level reporting. - Review and Assess Draft Templates and Guidance:
Examine CARB’s Draft Scope 1 and 2 Reporting Template for SB 253 to understand the data elements required—such as emissions by gas, boundary definitions, calculation methodologies, and verification documentation. For SB 261, review CARB’s Climate-Related Financial Risk Report Checklist to ensure that governance, strategy, risk management, and metrics align with TCFD and IFRS S2 frameworks. - Strengthen Data and Governance Infrastructure:
Begin mapping emissions data systems, internal controls, and documentation processes to ensure traceability and audit readiness. Companies should assess assurance readiness by identifying potential verification bodies and aligning internal reporting timelines to accommodate limited or reasonable assurance requirements. - Engage in Public Consultation:
CARB is actively soliciting feedback to refine reporting, verification, and timing provisions. Companies are encouraged to submit comments through the public docket by October 27, 2025, to help shape practical and industry-aligned final rules. - Coordinate Across Teams:
Successful compliance will require collaboration among sustainability, finance, legal, and risk management teams. Early coordination can help avoid duplication, identify data gaps, and establish consistent narratives across climate risk and GHG disclosures.
Trinity Consultants is closely monitoring CARB’s rule development and can help your organization stay ahead of compliance expectations. Our team supports clients with readiness assessments, disclosure gap analyses, and alignment of existing sustainability and GHG programs with SB 253 and SB 261 requirements. We also provide hands-on assistance with data collection, verification planning, and risk governance documentation to ensure your company is prepared when reporting becomes mandatory.
For any specific questions or to begin a consultation, please reach out to Charles C. Lee, PhD, CM, Principal Consultant or Divya Agarwal, Director of Sustainability
