Overview

• CARB’s Draft Checklist outlines minimum, TCFD-aligned disclosures on governance, strategy, risk management, and metrics and targets, with strategy resilience discussion allowed qualitatively and no scenario analysis required.
• For the initial filing, reporting Scope 1, 2, and 3 greenhouse gas emissions is not required, and any emissions figures included may be considered only if supported by independent third‑party assurance.
• Companies may use TCFD, IFRS S2, or another permitted government or exchange framework and must identify the chosen framework, note any omissions, and explain plans for future disclosures.
• The law applies to U.S. companies doing business in California with over $500 million in annual revenue, allows parent-level consolidated reporting in many cases, exempts certain regulated insurers, and calls for use of the most recent or best available data.
• Reports must be posted on company websites by January 1, 2026, with links submitted to a CARB public docket open December 1, 2025 through July 1, 2026, while CARB targets October 14 for draft rules and mid‑December for final regulations and litigation over the statutes continues on appeal.