{"$schema":"https://schema.org/Dataset","meta":{"name":"California SB 253: live regulatory tracker","description":"A dated, sourced record of every status change to California's Climate Corporate Data Accountability Act (SB 253) — rulemaking, guidance, litigation and deadlines — and what each one means for an SME supplier.","canonicalUrl":"https://ecodiligence.com/trackers/sb-253","jurisdiction":"California, United States","datePublished":"2026-09-07","dateModified":"2026-09-07","totalEvents":16,"confirmedEvents":12,"publisher":"EcoDiligence","license":"https://ecodiligence.com/terms","notice":"Recorded from public regulatory sources for orientation only; not legal advice. Entries whose `certainty` is not \"confirmed\", or which carry an `unverifiedNote`, are not asserted as established fact."},"currentStatus":{"headline":"First reports due November 10, 2026 — Scope 1 and Scope 2 only","detail":"CARB's September 1, 2026 guidance sets the first SB 253 reporting deadline at November 10, 2026, moved from August 10. That guidance describes the underlying Initial Regulation as pending approval by the Office of Administrative Law, so the deadline rests on CARB's published position rather than on a regulation that has completed review. SB 253 itself is not enjoined; the separate SB 261 reporting requirement is, pending appeal."},"upcoming":[{"id":"2026-11-10-first-reporting-deadline","date":"2026-11-10","recordedOn":"2026-09-07","title":"First SB 253 reports due — Scope 1 and Scope 2","description":"Under CARB's September 1, 2026 guidance, reporting entities would report Scope 1 and Scope 2 emissions for the applicable preceding fiscal year on or before November 10, 2026, subject to first-year enforcement discretion.","whatItMeans":"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.","kind":"deadline","certainty":"expected","supplierImpact":"act","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/2026-09/2026_SB253_Reporting_Guidance.pdf","name":"California Corporate Greenhouse Gas Reporting: Guidance for SB 253 2026 Reporting Submittals","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2027-scope-3-rulemaking","date":"2027-01-01","datePrecision":"year","recordedOn":"2026-09-07","title":"Second rulemaking to set 2027 reporting details, including Scope 3","description":"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.","whatItMeans":"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.","kind":"rulemaking","certainty":"expected","supplierImpact":"act","sources":[{"url":"https://ww2.arb.ca.gov/news/carb-approves-climate-transparency-regulation-entities-doing-business-california","name":"CARB approves climate transparency regulation for entities doing business in California","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]}],"history":[{"id":"2026-09-01-reporting-guidance","date":"2026-09-01","recordedOn":"2026-09-07","title":"CARB publishes 2026 reporting guidance and a voluntary intake platform","description":"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.","whatItMeans":"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.","kind":"guidance","certainty":"confirmed","supplierImpact":"act","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/2026-09/2026_SB253_Reporting_Guidance.pdf","name":"California Corporate Greenhouse Gas Reporting: Guidance for SB 253 2026 Reporting Submittals","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2026-07-27-fifteen-day-changes","date":"2026-07-27","recordedOn":"2026-09-07","title":"15-day changes move the deadline to November 10 and narrow the definitions","description":"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\".","whatItMeans":"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.","kind":"rulemaking","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2026/sb%20253-261/15_day_notice%20253-261.pdf","name":"Notice of Public Availability of Modified Text","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2026-06-23-oal-withdrawal","date":"2026-06-23","recordedOn":"2026-09-07","title":"CARB withdraws the package from OAL","description":"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.","whatItMeans":"The reason the regulation behind the November deadline had still not completed review by September 2026. The obligation is real; the instrument carrying it is not yet finished.","kind":"rulemaking","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2026/sb%20253-261/15_day_notice%20253-261.pdf","name":"Notice of Public Availability of Modified Text","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2026-05-20-oal-submission","date":"2026-05-20","recordedOn":"2026-09-07","title":"CARB submits the rulemaking package to OAL","description":"CARB submitted the rulemaking package for the Initial Regulation to the Office of Administrative Law for review on May 20, 2026.","whatItMeans":"Procedural — but worth recording, because of what happened to it five weeks later.","kind":"rulemaking","certainty":"confirmed","supplierImpact":"none","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2026/sb%20253-261/15_day_notice%20253-261.pdf","name":"Notice of Public Availability of Modified Text","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2026-02-26-board-approval","date":"2026-02-26","recordedOn":"2026-09-07","title":"CARB Board approves the Initial Regulation and sets an August 10 deadline","description":"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.","whatItMeans":"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.","kind":"rulemaking","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://ww2.arb.ca.gov/news/carb-approves-climate-transparency-regulation-entities-doing-business-california","name":"CARB approves climate transparency regulation for entities doing business in California","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"},{"url":"https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2026/sb%20253-261/15_day_notice%20253-261.pdf","name":"Notice of Public Availability of Modified Text (recites the February 26, 2026 approval)","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2026-01-09-ninth-circuit-argument","date":"2026-01-09","recordedOn":"2026-09-07","title":"Ninth Circuit hears oral argument; no decision issued","description":"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.","whatItMeans":"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.","kind":"litigation","certainty":"reported","supplierImpact":"watch","sources":[{"url":"https://www.climatecasechart.com/case/chamber-of-commerce-of-the-united-states-of-america-v-sanchez/","name":"Chamber of Commerce v. Sanchez — case record","publisher":"Sabin Center Climate Litigation Database","primary":false,"retrievedOn":"2026-09-07"}],"unverifiedNote":"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."},{"id":"2025-12-23-notice-of-hearing","date":"2025-12-23","recordedOn":"2026-09-07","title":"CARB posts the proposed regulation for 45-day comment","description":"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.","whatItMeans":"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.","kind":"rulemaking","certainty":"confirmed","supplierImpact":"none","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2025/sb253-261/notice1.pdf","name":"Notice of Public Hearing to Consider the Proposed Initial Regulation","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"},{"url":"https://ww2.arb.ca.gov/rulemaking/2025/california-corporate-greenhouse-gas-reporting-and-climate-related-financial-risk","name":"Rulemaking record: California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2025-11-18-ninth-circuit-injunction","date":"2025-11-18","recordedOn":"2026-09-07","title":"Ninth Circuit enjoins SB 261, declines to enjoin SB 253","description":"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.","whatItMeans":"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.","kind":"litigation","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://www.climatecasechart.com/document/chamber-of-commerce-of-the-united-states-of-america-v-sanchez_e075","name":"Order on motion for injunction pending appeal, Chamber of Commerce v. Sanchez, No. 25-5327 (9th Cir. Nov. 18, 2025)","publisher":"U.S. Court of Appeals for the Ninth Circuit (via the Sabin Center Climate Litigation Database)","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2025-10-10-draft-template","date":"2025-10-10","recordedOn":"2026-09-07","title":"CARB posts a draft Scope 1 & 2 reporting template","description":"CARB posted a Draft Scope 1 & Scope 2 GHG Reporting Template on October 10, 2025. Its use is voluntary for the 2026 reporting cycle.","whatItMeans":"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.","kind":"guidance","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/2026-09/2026_SB253_Reporting_Guidance.pdf","name":"Guidance for SB 253 2026 Reporting Submittals (states the October 10, 2025 template posting)","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2025-07-carb-faq","date":"2025-07-01","datePrecision":"month","recordedOn":"2026-09-07","title":"CARB publishes its climate-disclosure FAQ","description":"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.","whatItMeans":"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.","kind":"guidance","certainty":"confirmed","supplierImpact":"none","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/2025-07/FAQs%20Regarding%20California%20Climate%20Disclosure%20Requirements.pdf","name":"FAQs Regarding California Climate Disclosure Requirements","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}],"unverifiedNote":"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."},{"id":"2024-12-16-information-solicitation","date":"2024-12-16","recordedOn":"2026-09-07","title":"CARB opens its implementation information solicitation","description":"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.","whatItMeans":"Procedural. Useful only as the origin of the applicability definitions that were later argued over in the rulemaking.","kind":"rulemaking","certainty":"confirmed","supplierImpact":"none","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/2024-12/ClimateDisclosureQs_Dec2024.pdf","name":"Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2024-12-05-enforcement-notice","date":"2024-12-05","recordedOn":"2026-09-07","title":"CARB issues the first-year Enforcement Notice","description":"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.","whatItMeans":"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.","kind":"guidance","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://ww2.arb.ca.gov/sites/default/files/2024-12/The%20Climate%20Corporate%20Data%20Accountability%20Act%20Enforcement%20Notice%20Dec%202024.pdf","name":"The Climate Corporate Data Accountability Act Enforcement Notice","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"},{"url":"https://ww2.arb.ca.gov/sites/default/files/2026-09/2026_SB253_Reporting_Guidance.pdf","name":"Guidance for SB 253 2026 Reporting Submittals (states the December 5, 2024 cut-off)","publisher":"CARB","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2024-09-27-sb-219-signed","date":"2024-09-27","recordedOn":"2026-09-07","title":"SB 219 amends SB 253 and SB 261","description":"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.","whatItMeans":"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.","kind":"legislation","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240SB219","name":"SB-219 Greenhouse gases: climate corporate accountability: climate-related financial risk — bill text and status","publisher":"California Legislative Information","primary":true,"retrievedOn":"2026-09-07"}]},{"id":"2023-10-07-sb-253-signed","date":"2023-10-07","recordedOn":"2026-09-07","title":"Governor signs SB 253 into law","description":"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.","whatItMeans":"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.","kind":"legislation","certainty":"confirmed","supplierImpact":"watch","sources":[{"url":"https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240SB253","name":"SB-253 Climate Corporate Data Accountability Act — bill text and status","publisher":"California Legislative Information","primary":true,"retrievedOn":"2026-09-07"}]}]}