Overview

• CARB released a preliminary roster of roughly 4,100 entities it believes are covered, naming major utilities and energy manufacturers among those likely subject to the rules.
• The roster is provisional and shows errors such as duplicates, and CARB—using a broad “doing business in California” standard—is seeking corrections through a voluntary survey.
• Companies with more than $500 million in revenue must publish TCFD‑style climate‑risk reports by January 1, 2026 and biennially thereafter, with fines up to $50,000 for noncompliance.
• Companies with more than $1 billion in revenue must disclose Scope 1 and 2 emissions in 2026 with limited assurance and Scope 3 in 2027, with a potential June 30, 2026 start and penalties up to $500,000.
• A federal court denied a preliminary injunction on August 13; the appeal continues and trial is set for October 20, but a stay before the requirements take effect appears unlikely.