Overview

• CARB posted a non‑exhaustive preliminary list of companies it believes may be covered by SB 253 and SB 261, built from the California Secretary of State registry cross‑referenced with Dun & Bradstreet revenue data, and issued a voluntary survey to help validate the roster.
• The agency stresses the list is only a notice tool with gaps and possible duplicates, so each company must determine for itself whether it is subject to the laws.
• For SB 261, climate‑related financial risk reports must be published online by January 1, 2026, with CARB’s public docket accepting links starting December 1, 2025.
• For SB 253, CARB’s current proposal would require the first assured Scope 1 and Scope 2 emissions report for fiscal 2025 by June 30, 2026, with Scope 3 phased in starting 2027, subject to final rulemaking.
• CARB plans to release draft SB 253 reporting templates in early October and to issue a Notice of Proposed Rulemaking on October 14, opening a 45‑day comment period before Office of Administrative Law review.