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Regulatory Framework · California

California SB 253 & SB 261, explained

California's climate-disclosure laws require large companies doing business in the state to disclose greenhouse-gas emissions (SB 253) and climate-related financial risk (SB 261). Here is who they cover, how they reach suppliers, and how to prepare an emissions disclosure.

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Summary for orientation only. Thresholds and dates are administered by the California Air Resources Board (CARB) and may change — this is not legal advice.

The short version
  • SB 253 requires large companies doing business in California to disclose GHG emissions (Scope 1 and 2, later Scope 3).
  • SB 261 requires a climate-related financial risk report, along TCFD / IFRS S2 lines.
  • They reach companies anywhere that do enough business in California — headquarters location does not exempt you.
  • Most SMEs meet these laws indirectly: an in-scope customer needs Scope 3 data and asks suppliers for their emissions.
  • A standards-based ESG Passport with your Scope 1 and Scope 2 answers that request in minutes.

What is California SB 253?

SB 253, the Climate Corporate Data Accountability Act, is a California law requiring large companies that do business in the state to publicly disclose their greenhouse-gas emissions. It covers Scope 1 (direct emissions) and Scope 2 (purchased energy) first, with Scope 3 (value-chain emissions) phased in afterwards. The California Air Resources Board (CARB) is responsible for the detailed rules and the reporting schedule.

Because the trigger is “doing business in California” rather than being headquartered there, the law reaches a large number of national and international companies — and, through Scope 3, their suppliers.

What is California SB 261?

SB 261, the Climate-Related Financial Risk Act, is the companion law. Instead of an emissions inventory, it asks in-scope companies to publish a report describing the climate-related financial risks they face and the measures they are taking to reduce and adapt to those risks, following a recognised framework such as the TCFD recommendations (now carried forward through IFRS S2). Its revenue threshold is lower than SB 253's, so it captures a broader set of companies.

Who has to comply — and who just gets asked

There are two very different positions to be in:

Directly in scope

Large companies doing business in California

Above the revenue thresholds, a company files its own disclosures with CARB — emissions under SB 253, a climate financial-risk report under SB 261. Confirm the exact thresholds and dates against CARB's official pages.

Indirectly affected

Suppliers, including SMEs

You are unlikely to file anything with California yourself, but an in-scope customer needs Scope 3 data and will ask you for your Scope 1 and Scope 2 emissions. Answering well protects the commercial relationship.

How SB 253 reaches SMEs through Scope 3

Scope 3 is the emissions a company causes across its value chain — including the goods and services it buys (see our Scope 3 guide for what that means and what a proportionate answer looks like). When a large customer has to report Scope 3, the only way to get that number is to ask suppliers. That is why an SME with no California presence can still receive an “SB 253 questionnaire”: the customer is assembling its own value-chain figure and your emissions are one input.

You do not need to reproduce the customer's obligation. What helps them most is a clean, standards-based statement of your Scope 1 and Scope 2 emissions — exactly what an ESG Passport provides. If a request goes further than that, see our guide on answering a supplier ESG questionnaire and on the proportionate scope of buyer requests.

Go deeper on SB 253

How to prepare with EcoDiligence

Scope 1 & Scope 2 in minutes

Enter your fuel and electricity use; EcoDiligence calculates Scope 1 and Scope 2 (location-based) with the correct United States grid factor.

Sourced and transparent

Every emission factor names its source and vintage in the PDF — see the Methodology page for the full US factor table.

One answer, reused everywhere

A shareable Passport, a branded PDF, and machine-readable exports — hand the same link to every customer that asks.

Structured exports

Buyers who need structure receive the VSME Digital Template (Excel), which EFRAG's official converter turns into XBRL, from the same source of truth.

Create your free Passport, or read the Methodology to see exactly how the US emission factors are applied. Comparing that to hiring a consultant? See what an ESG report typically costs.

Frequently asked questions

It can. SB 253 is written to reach companies that do business in California above its revenue threshold, regardless of where they are headquartered. Beyond direct scope, many smaller companies feel the law indirectly: a large in-scope customer that must report its Scope 3 (value-chain) emissions will ask its suppliers — including SMEs anywhere — for their own emissions data.

They are two separate but related California laws. SB 253 (the Climate Corporate Data Accountability Act) is about disclosing greenhouse-gas emissions — Scope 1 and Scope 2, and, on a later phase, Scope 3. SB 261 (the Climate-Related Financial Risk Act) is about publishing a report on the climate-related financial risks the business faces and its response, along the lines of the TCFD / IFRS S2 framework. They have different revenue thresholds and different content.

As commonly summarised, SB 253 targets companies with total annual revenue above roughly USD 1 billion, and SB 261 companies above roughly USD 500 million, that do business in California. Thresholds and their precise definitions are set in statute and refined in CARB's rulemaking — confirm the current figures and how revenue is measured against the official sources before relying on them.

The reporting timeline is administered by the California Air Resources Board (CARB) and has been subject to legislative and regulatory amendment. Rather than quote a date that may have shifted, we point you to CARB's official implementation pages for the current schedule.

Almost certainly because that customer is (or expects to be) in scope and needs Scope 3 data, which includes emissions from its suppliers — you. You are generally not being asked to comply with SB 253 yourself; you are being asked for your own Scope 1 and Scope 2 figures so the customer can complete its value-chain picture. A standards-based ESG Passport answers that request cleanly.

EcoDiligence turns your energy and activity data into Scope 1 and Scope 2 (location-based) emissions using the correct United States grid factors, and produces a shareable Passport, a branded PDF, and machine-readable exports. It is a fast way to answer a customer's Scope 3 request — self-reported and clearly marked as not independently assured.

This page summarises California SB 253 and SB 261 for orientation only. It is not legal advice. Revenue thresholds, definitions, and reporting dates are set in statute and refined by CARB rulemaking, and have been amended over time; always confirm the current requirements with the California Air Resources Board before acting. EcoDiligence ESG Passports are self-reported summaries structured for ESG disclosure workflows, built on the EFRAG VSME Basic Module with optional IFRS S2 climate inputs. Content is not independently assured and does not constitute compliance, certification or an audit.

Answer a California Scope 3 request the smart way

Generate a shareable ESG Passport with your Scope 1 and Scope 2 emissions — free, ~10 minutes.