Regulatory Framework · California · Comparison
SB 253 vs. IFRS S2: the same data, different forms
A company preparing SB 253 disclosures and one preparing IFRS S2 are measuring almost the same emissions. Here is where the two line up, where the wording actually differs, and where one data set serves both.
Last updated:
Orientation only, current at the review date above. Not legal or accounting advice.
- Both use Scope 1 / 2 / 3 definitions consistent with the GHG Protocol — the same underlying basis.
- SB 253 is a California law with a CARB filing deadline. IFRS S2 is a global standard that binds a company only where a jurisdiction adopts it.
- SB 253's first phase is Scope 1 + 2 only (Scope 3 later); IFRS S2 asks for Scope 1, 2 and 3 plus a governance and strategy narrative.
- One dataset — activity data and a sourced emission factor — answers both; the wrapper around it differs.
- Full explainers: California SB 253 & SB 261 and ISSB S2 / IFRS S2.
Two different things wearing similar names
SB 253 is a California statute: it has a filing deadline, a regulator (CARB) that enforces it, and it binds entities that meet its revenue and California-nexus thresholds directly. IFRS S2 is a standard issued by the ISSB — it becomes mandatory only where a jurisdiction chooses to adopt or build on it. A company can be in scope of one, both, or neither, and the two questions are answered completely independently of each other.
Data-point mapping
| Data point | SB 253 | IFRS S2 | What a Passport carries |
|---|---|---|---|
| Scope 1 (direct emissions) | Required, first reporting phase | Required, part of Metrics & Targets | Calculated from fuel and vehicle activity data |
| Scope 2 (purchased energy) | Required, first phase, location-based | Required; location-based, market-based encouraged | Calculated from electricity use and a sourced grid factor |
| Scope 3 (value chain) | Required, later phase (previewed for 2027) | Required, with relief provisions in early adoption years | Not collected at category level; a Passport's Scope 1/2 can be one input to a customer's own Scope 3 |
| Governance narrative | Not required | Required — one of four core pillars | Not collected — outside a Passport's scope |
| Strategy & climate-risk narrative | Not required (that is SB 261's territory, separately) | Required — one of four core pillars | Not collected |
| Third-party assurance | Phased in for later reporting years; not required for the first (2026) cycle — schedule set by a separate future CARB rulemaking | Not mandated by the standard itself — depends on the adopting jurisdiction | Self-reported; not independently assured |
| Who has to report | Entities over ~$1B revenue doing business in California | Only where a jurisdiction has adopted or mandated it | SME suppliers usually report under neither — they answer a customer's request instead |
Where they diverge
The clearest gap is narrative: IFRS S2 is built on four pillars — governance, strategy, risk management, and metrics & targets — and only the last of those is an emissions number. SB 253 doesn't ask for the other three at all; it is an emissions-disclosure law, not a climate-risk framework. Going the other way, SB 253 carries something IFRS S2 does not itself provide: a specific filing deadline and a state regulator that enforces it. IFRS S2's enforcement, if any, comes entirely from whichever jurisdiction adopts it.
If you only have to answer one
Build the Scope 1 and Scope 2 figures once, from real activity data and a sourced, named emission factor. That number is valid input to either framework's request. What changes is the wrapper: an SB-253-driven request usually wants the number and its calculation basis; an IFRS-S2-driven one wants the number sitting inside a broader governance-and-strategy narrative that a Passport does not produce. Know which one you're actually being asked for before assuming one answer covers both.
Common questions
Reviewed on September 7, 2026. SB 253's assurance requirements for years after the first reporting cycle are set through a separate CARB rulemaking not yet finalised — treat that row of the table as directional, not a committed schedule. This page is orientation, not legal or accounting advice; confirm anything load-bearing against CARB, the IFRS Foundation, or a qualified adviser.
EcoDiligence ESG Passports are self-reported summaries structured for ESG disclosure workflows. Content is not independently assured. Information aligned with EFRAG VSME and IFRS S2 (ISSB) frameworks does not constitute formal compliance or certification.
One dataset, either wrapper
Generate Scope 1 and Scope 2 figures sourced and structured at a permanent link — free, ~10 minutes.