Overview

• CARB published a preliminary list on September 24 of entities it believes may fall under SB 253 emissions reporting and SB 261 climate‑risk disclosure, stressing the roster is not determinative of legal obligations.
• Staff compiled the list by cross‑referencing the California Secretary of State registry with commercial revenue data such as Dun & Bradstreet, and the agency notes gaps, partial name matches, duplicates and possible exemptions in the dataset.
• Companies are asked to provide input through a voluntary online survey, with CARB also accepting implementation feedback via [email protected].
• CARB staff estimate roughly 2,600 companies could be subject to SB 253 and about 4,100 to SB 261, pending refinement of scope definitions and further rulemaking.
• Draft guidance for initial SB 261 reports follows TCFD‑style pillars and permits frameworks such as IFRS S2, does not require GHG emissions in the first SB 261 filing, and sets an initial report due date of January 1, 2026.