Overview

• The preliminary list identifies about 4,100 entities across sectors, including major utilities and manufacturers such as PG&E, Southern California Edison, NRG Energy and Berkshire Hathaway Energy.
• CARB stresses that inclusion or omission is not determinative and asks companies to self-assess applicability of SB 253 (> $1 billion revenue) and SB 261 (> $500 million) while submitting validation through a voluntary survey.
• The roster was built by cross-referencing California Secretary of State filings with Dun & Bradstreet revenue data, a method that produced temporal gaps and roughly 1,000 apparent duplicates, according to legal analysts.
• Rulemaking continues following an Aug. 13 denial of a preliminary injunction, with a proposed regulation expected around Oct. 14 to clarify revenue calculations and what constitutes doing business in California.
• Key timelines remain: SB 261 climate-risk reports are due Jan. 1, 2026; SB 253 Scope 1 and 2 emissions reporting begins in 2026 with Scope 3 starting in 2027, and penalties can reach up to $500,000 per year under SB 253 and $50,000 under SB 261.