Live tracker · California, United States
California SB 253: live regulatory tracker
Every change in the status of California's Climate Corporate Data Accountability Act, dated and linked to the document it came from — plus what each one actually means if you are a supplier being asked for emissions data.
Last updated:
Status as of October 13, 2026
First reports due November 10, 2026 — Scope 1 and Scope 2 only
The Office of Administrative Law approved CARB's Initial Regulation on October 12, 2026, effective the same day, so the November 10, 2026 deadline for first Scope 1 and Scope 2 reports is now set in a regulation in force (17 CCR § 96076(a)), moved from August 10. SB 253 itself is not enjoined; the separate SB 261 reporting requirement is, pending appeal.
Cite this page as: EcoDiligence, “California SB 253: live regulatory tracker”, https://ecodiligence.com/trackers/sb-253 (last updated October 13, 2026). Every entry links to the document it came from; where we could not confirm something against a primary source, the entry says so rather than guessing.
What is still ahead
Scheduled or announced, not yet happened. Dates shown at the precision the regulator has actually published.
- RulemakingWorth watching
CARB Board hears an informational update on the program
The agenda for the October 22, 2026 CARB Board meeting lists item 26-7-1, an informational update on the California Corporate Greenhouse Gas Reporting Program that includes external experts. The agenda states that staff are developing concepts for a future proposed regulation that would build on first-year Scope 1 and Scope 2 reporting and include Scope 3. It is an informational item, not a vote.
What it means for an SME supplier
No new obligation comes out of an informational item. It is the first public look at how Scope 3 — the part that eventually reaches supplier data — may be shaped, so it is worth watching rather than acting on.
- DeadlineSuppliers may need to act
First SB 253 reports due — Scope 1 and Scope 2
Under 17 CCR § 96076(a), in force since October 12, 2026, reporting entities must report Scope 1 and Scope 2 emissions for the applicable preceding fiscal year on or before November 10, 2026, with the first-year options in § 96076(b).
What it means for an SME supplier
If a covered customer is going to ask you for emissions data this year, the weeks before this date are when it happens. Having a Scope 1 and Scope 2 figure ready — with the factor and source stated — is the whole of the preparation an SME supplier needs.
- RulemakingSuppliers may need to act
Second rulemaking to set 2027 reporting details, including Scope 3
CARB has stated that SB 253 requires Scope 3 reporting beginning in 2027 and that a subsequent, separate rulemaking will establish reporting details and deadlines for 2027 and beyond. No 2027 deadline had been set at this page's last update.
What it means for an SME supplier
This is the step that turns SB 253 from a large-company obligation into a supplier data request at scale — Scope 3 is, by definition, your emissions in your customer's report. 2027 is the year CARB has named; no date within it has been published, which is why none is shown here.
The record so far
Newest first. 16 entries.
- RulemakingSuppliers may need to act
OAL approves the Initial Regulation; the November 10 deadline is now in force
The Office of Administrative Law approved the Initial Regulation (17 CCR §§ 96070–96077) on October 12, 2026, with an effective date of October 12, 2026. Section 96076(a) requires each reporting entity to report Scope 1 and Scope 2 emissions for the applicable preceding fiscal year on or before November 10, 2026. Section 96076(b) allows, for that first report only, Scope 1 and Scope 2 emissions determined from information the entity already possessed or was collecting on or before December 5, 2024, or a statement on letterhead that it held no such information. In October 2026 CARB also wrote to organizations that may be subject to the program, repeating the deadline and the § 96076(b) options.
What it means for an SME supplier
The date your customer is working to is no longer a CARB position awaiting review; it is in a regulation in force. The first-year relief in § 96076(b) means a covered customer can file on data it already had, so a request to you this cycle is their choice, not something the regulation requires of a supplier. Scope 3 is still not part of this deadline.
- Primary source — California Corporate Greenhouse Gas Reporting: Notice of Office of Administrative Law Approval (CARB)
- Primary source — Final Regulation Order: California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation (CARB)
- Primary source — Potential Applicability: California Corporate Greenhouse Gas Reporting and Fees (CARB)
- RulemakingWorth watching
CARB resubmits the rulemaking package to OAL
CARB resubmitted the final rulemaking package for the Initial Regulation to the Office of Administrative Law on September 21, 2026, under Executive Order R-26-006 signed that day. With it, CARB asked OAL to make the regulation effective on filing with the Secretary of State, citing the November 10, 2026 reporting deadline.
What it means for an SME supplier
A procedural step. Nothing changes for a supplier until OAL decides; it is recorded because it is what made the October approval possible before the November deadline.
- Agency guidanceSuppliers may need to act
CARB publishes 2026 reporting guidance and a voluntary intake platform
CARB's Guidance for SB 253 2026 Reporting Submittals, dated September 1, 2026, states that reporting entities would report Scope 1 and Scope 2 emissions for the applicable preceding fiscal year on or before November 10, 2026. It describes the Initial Regulation as applying "if approved by the Office of Administrative Law". It sets out acceptable formats — an existing annual report, data already reported to other programmes, CARB's draft template, or a statement of non-reporting on company letterhead — offers a voluntary intake platform and a climatedisclosure@arb.ca.gov mailbox, allows eGRID 2023 or alternative credible emission factors for Scope 2, and states that submissions will be accepted whether or not limited assurance has been obtained.
What it means for an SME supplier
The most useful entry on this page for a supplier. Two things follow from it. First, your customer has wide latitude in what it files this cycle, so a request for perfectly assured data is their preference, not California's requirement. Second, the emission-factor language is unusually permissive — a Scope 2 figure calculated with published grid factors and a stated source meets what CARB is asking for in the first cycle.
- RulemakingWorth watching
15-day changes move the deadline to November 10 and narrow the definitions
CARB published modified regulatory text on July 27, 2026 with a comment deadline of August 11, 2026. The notice describes a revised November 10 reporting deadline in section 96076(a), and correspondingly moves the fee determination notice from September 10 to December 10. Other proposed changes clarify "doing business in California", exclude intercompany transactions within a combined reporting group from the revenue test, and revise the definition of "subsidiary".
What it means for an SME supplier
Three months of extra room for every covered customer — which in practice moves the supplier-data requests too. The revenue clarification also matters: measuring revenue at the individual entity level, net of intercompany transactions, changes which group members are in scope at all.
- RulemakingWorth watching
CARB withdraws the package from OAL
On June 23, 2026 CARB withdrew the Initial Regulation and the associated rulemaking documents from OAL review, stating that it was doing so to allow more time to make limited changes clarifying certain provisions.
What it means for an SME supplier
The reason the regulation behind the November deadline had still not completed review by September 2026. It completed review on October 12, 2026 (see below).
- RulemakingNo supplier action
CARB submits the rulemaking package to OAL
CARB submitted the rulemaking package for the Initial Regulation to the Office of Administrative Law for review on May 20, 2026.
What it means for an SME supplier
Procedural — but worth recording, because of what happened to it five weeks later.
- RulemakingWorth watching
CARB Board approves the Initial Regulation and sets an August 10 deadline
At its February 26, 2026 hearing the Board approved for adoption sections 96070–96077 of Title 17, establishing a fee program, key applicability definitions, and a first-year reporting deadline. CARB's announcement states that the Board set August 10, 2026 as SB 253's first-year deadline and that first-year reporting covers Scope 1 and Scope 2 only, with Scope 3 beginning in 2027.
What it means for an SME supplier
The first date a supplier could plan around — and, as the entries below show, not the final one. If your customer's ESG team quotes an August deadline, they are working from this announcement rather than from CARB's current position.
- LitigationWorth watchingSecondary sourcing
Ninth Circuit hears oral argument; no decision issued
A Ninth Circuit panel heard oral argument in the appeal challenging SB 253 and SB 261 on First Amendment grounds. No merits decision had issued as of this page's last update.
What it means for an SME supplier
The open question over the whole timeline. A decision could leave SB 253 as it is, or unsettle the November deadline entirely. Until it lands, the deadline below is the one to plan against.
Not fully verified. The argument date and the absence of a decision come from secondary reporting; we have not read the Ninth Circuit docket directly. Treat the date as approximate and check the docket before relying on it.
No primary document is linked for this entry yet.
- RulemakingNo supplier action
CARB posts the proposed regulation for 45-day comment
CARB posted the Notice of Public Hearing and the proposed text of the California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation on December 23, 2025, setting a public hearing for February 26, 2026.
What it means for an SME supplier
Procedural, but it is the text that later defines who counts as a reporting entity and how revenue is measured — the questions that decide whether a given customer of yours is covered at all.
- LitigationWorth watching
Ninth Circuit enjoins SB 261, declines to enjoin SB 253
In Chamber of Commerce v. Sanchez, No. 25-5327, the Ninth Circuit granted an injunction pending appeal against enforcement of SB 261 and denied the same relief as to SB 253. SB 261 had required a report by January 1, 2026.
What it means for an SME supplier
The single most misreported point about this law. The climate-risk reporting law (SB 261) was paused; the emissions reporting law (SB 253) was not. If a customer tells you their California obligation has been struck down, that is true of SB 261 only.
- Agency guidanceWorth watching
CARB posts a draft Scope 1 & 2 reporting template
CARB posted a Draft Scope 1 & Scope 2 GHG Reporting Template on October 10, 2025. Its use is voluntary for the 2026 reporting cycle.
What it means for an SME supplier
The closest thing to a shape for the answer your customer has to produce. A supplier is not asked to fill this in — but the categories in it are the categories a customer's request tends to inherit.
- Agency guidanceNo supplier action
CARB publishes its climate-disclosure FAQ
CARB published a Frequently Asked Questions document on the California climate-disclosure requirements. CARB's later guidance relies on this FAQ, together with the December 2024 Enforcement Notice, as the basis for first-year enforcement discretion.
What it means for an SME supplier
The FAQ is where a covered customer's compliance team is most likely to have read what it can and cannot ask of you for the first cycle.
Not fully verified. Dated to July 2025 from CARB's own file path for the document; the publication day is not stated on the face of the file we retrieved, so this entry is shown at month precision.
- RulemakingNo supplier action
CARB opens its implementation information solicitation
CARB published a solicitation dated December 16, 2024 seeking stakeholder input on implementing SB 253 and SB 261 as amended by SB 219, including whether to adopt the Revenue and Taxation Code section 23101 interpretation of "doing business in California". The comment period ran to February 14, 2025.
What it means for an SME supplier
Procedural. Useful only as the origin of the applicability definitions that were later argued over in the rulemaking.
- Agency guidanceWorth watching
CARB issues the first-year Enforcement Notice
CARB published an Enforcement Notice for the Climate Corporate Data Accountability Act in December 2024, exercising enforcement discretion for the first report due in 2026. Reporting entities may submit Scope 1 and Scope 2 emissions based on information they already had or were already collecting when the notice was issued; CARB's later guidance identifies that date as December 5, 2024.
What it means for an SME supplier
This is the reason a covered customer may not be chasing you yet. For the first cycle a covered entity can report from data it already had, which for many means no new supplier data collection at all — and for others, an early request precisely because they want to be ready for the cycles that follow.
- LegislationWorth watching
SB 219 amends SB 253 and SB 261
SB 219 was approved by the Governor and filed with the Secretary of State on September 27, 2024, as Chapter 766. It amends Health and Safety Code sections 38532 and 38533, including provisions allowing reports to be consolidated at the parent-company level: where a subsidiary qualifies as a reporting entity, the subsidiary is not required to prepare a separate report.
What it means for an SME supplier
Explains why a customer's request may arrive from a parent company rather than the entity you actually invoice. It also means the same corporate group asks once, not once per subsidiary.
- LegislationWorth watching
Governor signs SB 253 into law
SB 253, the Climate Corporate Data Accountability Act, was approved by the Governor and filed with the Secretary of State on October 7, 2023, as Chapter 382. It requires US-based entities with more than USD 1 billion in annual revenue doing business in California to report Scope 1, Scope 2 and Scope 3 greenhouse-gas emissions.
What it means for an SME supplier
The starting point for every date below. Nothing here obliges an SME directly — the threshold is a billion dollars of revenue — but it is the law your large customers are eventually reporting under, and Scope 3 is the clause that reaches you.
Frequently asked questions
This tracker records publicly available regulatory developments for orientation only and is not legal advice. Thresholds, definitions and dates are set in statute and refined through CARB rulemaking, and have changed more than once; confirm the current position with the California Air Resources Board before acting. First published September 7, 2026. 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.
Get ahead of the request instead of reacting to it
If a covered customer asks for your emissions, a standards-based ESG Passport answers it once and is reusable for the next customer. Free, self-reported, about ten minutes.