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Regulatory Framework · California · Status Update

SB 253's first deadline: what actually changed in 2026

CARB pushed the first SB 253 reporting deadline from August 10 to November 10, 2026, and companion law SB 261 has been on hold since a Ninth Circuit order in late 2025. Here is the current status, checked against the court's own order and CARB's rulemaking notices.

Last updated:

Prepare your figures nowThe full SB 253 & SB 261 guide

This is the most volatile page on the site by design — the rulemaking has moved twice already. Treat every date here as current at the review date above, not permanent, and confirm anything load-bearing with CARB directly.

The short version
  • New deadline: November 10, 2026 for first Scope 1 + Scope 2 reports (was August 10, 2026).
  • Why: CARB withdrew its regulation from OAL on June 23, 2026 to make changes, then released revised text on July 27, 2026. OAL approved the revised regulation on October 12, 2026, effective that day.
  • SB 261 (the separate climate financial-risk law) is not being enforced right now — the Ninth Circuit enjoined it on November 18, 2025, pending appeal.
  • That injunction does not touch SB 253 — the same order explicitly denied the motion as to SB 253.
  • Scope 3 is a separate, later phase (2027), not part of this deadline.

The timeline so far

DateEventDetail
Aug 10, 2026Original statutory deadlineSB 253's first Scope 1 and Scope 2 reports were originally due on this date.
Jun 23, 2026CARB withdraws its package from OALCARB pulled its submitted regulation from the Office of Administrative Law to make limited changes and clarify requirements, including how the applicability thresholds apply to corporate affiliates.
Jul 27, 2026CARB releases modified textA 15-day public comment period opened, closing Aug 11, 2026. The modified text proposed the new November date.
Sep 21, 2026CARB resubmits the package to OALCARB resubmitted the final package to the Office of Administrative Law and asked for it to take effect on filing, citing the November deadline.
Oct 12, 2026OAL approves the regulationThe Initial Regulation (17 CCR §§ 96070–96077) took effect the same day, per CARB's notice of OAL approval.
Nov 10, 2026New first-report deadlineThe deadline for initial Scope 1 and Scope 2 disclosures, set in 17 CCR § 96076(a) of the regulation in force since Oct 12, 2026.
A moving part, flagged deliberately

CARB submitted its initial regulation to the Office of Administrative Law, then withdrew it on June 23, 2026 to give reporting entities more time and to clarify requirements — including how the revenue and California-nexus thresholds apply when a company sits inside a group of affiliates. The revised text released July 27, 2026 proposed the current November 10, 2026 date and closed its comment period on August 11, 2026.

CARB resubmitted the package to OAL on September 21, 2026, and, according to CARB's notice, OAL approved it on October 12, 2026, effective that day. The November 10 date now sits in the regulation itself (17 CCR § 96076(a)). If you are making a decision that turns on this exact date, check CARB's own page rather than this one — it was last reviewed on October 13, 2026.

What's actually due November 10, 2026

Scope 1 and Scope 2 only, for entities actually in scope of SB 253 (see who is actually covered). Scope 3 — the value-chain figure that eventually pulls in supplier data — is a distinct, later phase that CARB has previewed for 2027, not part of this deadline. Don't let a customer request that mentions “SB 253” and “Scope 3” in the same sentence imply that Scope 3 reporting is due now; it usually means the customer is preparing ahead of the later phase.

SB 261 is a different law, and it's frozen

SB 261, the Climate-Related Financial Risk Act, is a separate statute from SB 253 with its own $500 million revenue threshold and its own biennial reporting requirement. On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit granted an injunction pending appeal in Chamber of Commerce v. Randolph (Case No. 25-5327) — days before SB 261's original January 1, 2026 reporting deadline. The order's own language is unambiguous: the motion was granted as to SB 261 and denied as to SB 253.

An injunction pending appeal is a temporary posture, not a ruling on the merits — it pauses enforcement while the case is decided, and it can be lifted, narrowed, or upheld depending on how that appeal resolves. Oral argument has been held; there is no final ruling as of this page's review date. If SB 261 reaches you directly, check the current docket status before assuming either that it is dead or that it will resume on any particular date.

If you're a supplier, not the filer

None of this changes what a supplier is actually asked to do. Your customer's deadline moving does not move yours, and the SB 261 injunction does not touch the Scope 1 and Scope 2 request most suppliers receive. See SB 253 for suppliers for exactly what to send back and what you can decline.

Common questions

November 10, 2026, for initial Scope 1 and Scope 2 disclosures — moved from the original August 10, 2026 date. CARB proposed the date in its July 27, 2026 modified regulatory text, and the Office of Administrative Law approved the regulation on October 12, 2026, effective that day, so the date is now set in 17 CCR § 96076(a). Check CARB's own page for anything later; this area has moved before.

CARB withdrew its submitted regulatory package from the Office of Administrative Law on June 23, 2026 — in CARB's own words, “to allow more time to make limited changes to clarify certain provisions.” It published a Notice of Upcoming Rulemaking Update the following day. The revised text released on July 27, 2026 proposed the three-month extension.

No. The Ninth Circuit granted an injunction pending appeal on November 18, 2025 — a temporary pause while the underlying legal challenge is decided, not a ruling that the law is invalid or a repeal. The case remains active; an injunction pending appeal can be lifted, narrowed, or made permanent depending on how the appeal resolves.

No. The same order (Ninth Circuit, Case No. 25-5327) is explicit: the motion was "granted as to the enforcement of Senate Bill 261 and denied as to the enforcement of Senate Bill 253." SB 253's Scope 1 and Scope 2 reporting obligations are unaffected by that ruling.

Scope 1 (direct) and Scope 2 (purchased energy) emissions only, for entities actually in scope of SB 253. Scope 3 (value-chain emissions) is a separate, later phase — CARB has previewed 2027 for that framework, not this deadline.

CARB's own Climate Corporate Data Accountability program page carries the authoritative rulemaking timeline and current deadline. Treat any third-party summary — including this one — as a starting point, not the final word.

Whatever the current deadline is, the underlying task doesn't change: an SME supplier needs a clean Scope 1 and Scope 2 figure to hand its customer. EcoDiligence produces that as a Passport with those Scope 1 and 2 figures — self-reported, sourced, and not independently assured.

Every date on this page was current as of October 13, 2026. The SB 261 injunction date and scope were checked against the Ninth Circuit's own order (Case No. 25-5327, filed Nov 18, 2025); the deadline-reset dates were checked against multiple independent legal summaries of CARB's own notices, not CARB's raw text directly. This rulemaking has changed more than once and can change again — confirm anything load-bearing with CARB's program page or a qualified adviser. This page is orientation, not legal advice.

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.

Whatever the date, the data doesn't change

Generate a shareable Passport with your SB 253 Scope 1 and Scope 2 emissions — free, ~10 minutes.

Create free PassportRead the full SB 253 guide