Overview

• CARB published a preliminary roster of 4,159 companies it believes may fall under SB 253 and SB 261 and opened a voluntary survey to validate the list.
• The roster was compiled from California Secretary of State records through March 2022 and cross‑referenced with Dun & Bradstreet revenue data, and CARB stresses it is not determinative.
• SB 261 climate‑related financial risk reports are due January 1, 2026, with CARB’s public docket set to accept report links beginning December 1, 2025.
• CARB staff has proposed the first SB 253 Scope 1 and Scope 2 emissions submissions as early as June 30, 2026, with Scope 3 reporting slated to begin in 2027 for the prior fiscal year.
• Draft SB 253 templates are expected in early October, and CARB plans to issue a Notice of Proposed Rulemaking on October 14 that would start a 45‑day comment period, as litigation continues without a stay.