Summary
What must you file under California SB 253 by November 10, 2026? US-organized companies with more than $1 billion in annual revenue that do business in California must submit Scope 1 and Scope 2 emissions for their prior fiscal year. The California Air Resources Board (CARB) will not require third-party assurance this year. Penalties reach $500,000 per reporting year, although CARB signals good-faith enforcement discretion for the first cycle. Scope 3 reporting starts in 2027. If you have data gaps, file what you have and document the rest.
Not legal advice. This article is general information for businesses, based on official sources checked in October 2026. Laws, thresholds and deadlines change, and how they apply depends on your company’s facts. Check the current text of each law or ask a qualified lawyer before you act.
The clock is short. CARB moved the first SB 253 deadline from August 10 to November 10, 2026, and the Office of Administrative Law approved CARB’s initial regulation on October 12, 2026. That leaves days, not months, for any company that has not started.
This guide works as a last-mile checklist. It explains who files, what goes into the first report, how to handle missing data, and what changes in 2027. It also shows how the California rule connects to reporting duties in Germany, the wider EU, the UK, and Canada. For the full regime comparison, read our carbon reporting requirements guide.
What Is Due on November 10, 2026 Under SB 253?
Covered companies must report Scope 1 and Scope 2 greenhouse gas emissions for their prior fiscal year by November 10, 2026. Scope 1 means direct emissions from sources you own or control, such as boilers and company vehicles. Scope 2 means indirect emissions from purchased electricity, steam, heating, and cooling.
The law is the Climate Corporate Data Accountability Act (SB 253). CARB administers and enforces it. CARB’s guidance of September 3, 2026 says the calculations must follow the Greenhouse Gas Protocol. Your submission should explain organizational boundaries, data sources, emission factors, assumptions, estimates, and exclusions.
| Date | Event |
|---|---|
| December 5, 2024 | CARB issues its first enforcement notice |
| February 26, 2026 | CARB first approves the initial regulation |
| September 3, 2026 | CARB publishes first-year reporting guidance |
| October 12, 2026 | Office of Administrative Law approves the regulation; it takes effect immediately |
| November 10, 2026 | First Scope 1 and Scope 2 reports due |
| 2027 | Scope 3 reporting begins; assurance rules expected through separate rulemaking |
Who Has to File?
A US-organized entity with more than $1 billion in total annual revenue that does business in California must file. The revenue test applies at the appropriate parent level, so consolidated revenue matters. Subsidiaries, joint ventures, and private equity structures can make this question hard.
CARB’s initial regulation defines the key terms, including what counts as doing business in California. Read those definitions before you decide that you fall outside the law. A group with a German or other foreign parent should ask counsel how the rule treats its US subsidiaries, because the law targets US-organized entities.
What Happens If You Do Not Have Complete Data?
You still file, but you can document the gaps. CARB said it will use enforcement discretion in the first cycle for companies that make a good-faith effort. That discretion does not remove the duty to report.
One narrow relief exists. A company that was not collecting, and did not plan to collect, Scope 1 and Scope 2 data when CARB issued its December 5, 2024 notice may submit a statement of non-reporting on company letterhead. This is not a permanent exemption. Treat it as a one-year bridge, and start collecting data now.
- Estimate where needed: Use utility bills, fuel purchase records, and published emission factors, and state each assumption
- Explain exclusions: Name any facility or source you left out and give the reason
- Keep your records: Store invoices, meter reads, and calculation files so you can defend the numbers later
- Report both Scope 2 methods: Where you can, show location-based and market-based figures, as the GHG Protocol expects
Is Third-Party Assurance Required This Year?
No. CARB accepts 2026 submissions whether or not you obtained limited assurance. Expect that to change. CARB plans a separate rulemaking for 2027 and later, and independent assurance will likely feature in it.
Practical advice follows from that. If you can afford a readiness review this year, do it. An internal check now shortens the audit later, especially when your Scope 1 and Scope 2 data sit in several systems.
What Are the Penalties for Missing the Deadline?
CARB can assess administrative penalties of up to $500,000 per reporting year for non-filing, late filing, and other reporting failures. The initial regulation also sets an annual administration fee. Check CARB’s current fee schedule, because the amount can change with the California Consumer Price Index.
For Scope 3, penalties between 2027 and 2030 apply only to non-filing. That gives companies time to improve value chain data. It does not give them time to ignore it. Our guide to ESG non-compliance penalties compares this exposure with other regimes.
What About SB 261 and the Court Challenges?
The Ninth Circuit has enjoined enforcement of SB 261, the biennial climate-risk reporting law, while the appeal continues. CARB has said it will not enforce SB 261 during the injunction. The court has not enjoined SB 253, so the November 10 deadline stands.
Both laws remain in litigation. Plan for SB 253 now, and watch the appeal for any change. Our overview of US environmental regulations for businesses tracks the federal side, including the stayed SEC climate rule.
How Does SB 253 Connect to Reporting in Germany, the EU, the UK, and Canada?
The four markets share the GHG Protocol, but their triggers and deadlines differ. A multinational can reuse one emissions inventory for several filings if it sets the boundaries consistently from the start.
| Market | Rule | Who | Key Date or Status |
|---|---|---|---|
| California, US | SB 253 | US-organized entities above $1B revenue doing business in California | First report November 10, 2026 |
| EU, including Germany | CSRD after Omnibus I, Directive (EU) 2026/470 | More than 1,000 employees and more than EUR 450M turnover | Second-wave reports in 2028 on financial year 2027; Member State transposition by March 19, 2027 |
| UK | SECR; UK Sustainability Reporting Standards | Large and quoted companies (SECR) | UK standards voluntary; FCA proposes listed-company use from January 1, 2027 |
| Canada | No mandatory economy-wide regime | CSDS 1 and CSDS 2 voluntary | Canadian Securities Administrators paused their project on April 23, 2025 |
A German group that already reports under the CSRD holds most of the data SB 253 asks for. Its main task is to confirm that the California boundary and fiscal year match its other reports. A UK company with a US parent should check which entity files in California.
What Should You Do in the Next Days?
- Confirm applicability. Test revenue at the parent level and read CARB’s definition of doing business in California
- Fix your reporting period. Use the prior fiscal year and write down the dates
- Set the boundary. Choose operational or financial control and apply it consistently
- Collect Scope 1 data. Gather fuel, refrigerant, and fleet records for every site
- Collect Scope 2 data. Gather electricity and heat bills, and any renewable energy certificates
- Document methods. Record emission factors, assumptions, estimates, and exclusions
- Review and approve. Have finance and sustainability leads sign off before submission
- Submit on CARB’s platform before November 10. Keep proof of submission
- Plan 2027. Start a Scope 3 screening and budget for assurance
California SB 253 Filing Checklist (2026)
- [ ] Parent-level revenue test completed and documented
- [ ] Doing-business-in-California analysis completed
- [ ] Prior fiscal year and organizational boundary fixed
- [ ] Scope 1 and Scope 2 inventory calculated under the GHG Protocol
- [ ] Methods, emission factors, estimates, and exclusions written down
- [ ] Internal sign-off recorded
- [ ] Submission made before November 10, 2026, with proof saved
- [ ] Annual CARB fee checked and paid
- [ ] 2027 Scope 3 and assurance plan started
Official methodology sits with the GHG Protocol Corporate Standard. Check CARB’s own website for the current portal, forms, and fee schedule before you submit.
Frequently Asked Questions
When is the first SB 253 report due?
November 10, 2026. CARB moved the date from August 10, 2026, and the regulation took effect on October 12, 2026.
Which emissions must the first report cover?
Scope 1 and Scope 2 for the prior fiscal year, calculated under the GHG Protocol. Scope 3 starts in 2027.
Does the first report need third-party assurance?
No. CARB accepts 2026 submissions with or without limited assurance. Later rulemaking is expected to address assurance.
What is the maximum SB 253 penalty?
Up to $500,000 per reporting year. CARB has signalled good-faith enforcement discretion for the first cycle.
Is SB 261 blocked by the courts?
The Ninth Circuit has enjoined SB 261 pending appeal. It has not enjoined SB 253, so the November 10 duty stands.
Can a company skip the report if it has no emissions data?
Only a company that was neither collecting nor planning to collect Scope 1 and Scope 2 data at CARB’s December 5, 2024 notice may file a statement of non-reporting. It is a one-year bridge, not a permanent exemption.
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