The California Air Resources Board (CARB) has set Nov. 10, 2026, as the first-year deadline for Scope 1 and Scope 2 greenhouse gas emissions reports under California’s Climate Corporate Data Accountability Act (SB 253).
The law covers U.S.-formed business entities with more than $1 billion in total annual revenue that meet California’s “doing business” test – even if they have no California office, employees, or other physical presence. The reporting deadline and coverage criteria make SB 253 relevant to companies beyond those headquartered or operating physically in the state.
Key Points
- The first-year deadline for Scope 1 and Scope 2 emissions reports is Nov. 10, 2026. CARB extended the deadline from Aug. 10,2026. This is a one-time deadline for the first reporting year.
- Coverage depends on revenue and California sales — not necessarily physical presence.
- Non-compliance carries civil penalties of up to $500,000 per reporting year, assessed by CARB.
- CARB’s fee-notice date is Dec. 10, 2026. Covered entities must pay the fee within 60 calendar days of the invoice, whether or not they submit emissions data that year.
- SB 253 is in effect and has not been enjoined. Enforcement of the related climate-risk law, SB 261, remains paused by a Ninth Circuit injunction.
Continue reading the full GT Alert.
*Special thanks to Law Clerk/JD Ryan Joy for contributing to this GT Alert.