California continues to move forward on implementation of its two landmark climate disclosure laws — SB 253, the Climate Corporate Data Accountability Act, and SB 261, the Climate-Related Financial Risk Act. Over the past few weeks, the California Air Resources Board (CARB) has released several important materials that set the stage for how companies will report their emissions and climate risks in 2026 and beyond.

1. Draft Template Released for SB 253: Scope 1 and 2 Emissions Reporting

On October 10, 2025, CARB published a draft Excel template for reporting Scope 1 (direct) and Scope 2 (purchased energy) greenhouse-gas (GHG) emissions. This marks the first concrete step toward operationalizing SB 253, which requires U.S. companies doing business in California with over $1 billion in annual revenue to disclose their GHG emissions annually.

What’s in the Template

The proposed template covers:

• Organizational information (entity name, headquarters, industry code, EIN, and contact details)

• Third-party verification (confirmation of limited assurance for Scope 1 and 2 emissions, plus verifier details)

• Inventory boundaries (equity share, financial control, or operational control — with lists of included/excluded entities)

• Emission details for Scope 1 and 2, including intensity per million dollars of revenue

• Methodology and emission factors used in calculations

• De minimis sources (small or immaterial emissions)

• Alignment with other CARB programs, such as the Mandatory Reporting Regulation (MRR)

• Optional fields for future years, including breakdowns by emission source, GHG type, and base-year comparisons

Key Points for Companies

• Use of the template is voluntary for 2026 (covering FY 2025).

• Scope 3 (value-chain) reporting will follow in 2027, with a separate template expected next year.

• Public comments are open until October 27, 2025, via CARB’s online docket or email (climatedisclosure@arb.ca.gov).

Why This Matters

Although voluntary, the draft template effectively reveals CARB’s data structure for upcoming years. Aligning internal systems to it now can save time later if fields become mandatory. Companies should start mapping their existing GHG inventories, verify boundary selections, and prepare to obtain limited assurance for Scopes 1–2.

2. SB 261 Climate-Risk Checklist: Aligning With TCFD and ISSB

For companies subject to SB 261 — those with over $500 million in annual revenue — CARB has also issued a draft Climate-Related Financial Risk Report Checklist (September 2, 2025). The checklist mirrors the structure of global frameworks such as the Task Force on Climate-Related Financial Disclosures (TCFD) and the International Sustainability Standards Board (ISSB) standards, covering governance, strategy, risk management, and metrics/targets.

This checklist is not a template but a reference tool to help companies structure their first climate-risk reports, which are due January 1, 2026.

3. Preliminary List of Covered Entities and Voluntary Survey

On September 24, 2025, CARB published a preliminary list of potentially covered companies and a voluntary survey tool to confirm or correct that list. While inclusion on the list doesn’t definitively determine regulatory coverage, CARB is using the data to refine definitions and fee structures under both SB 253 and SB 261. Companies should review the list and submit the survey if they believe their inclusion or omission is incorrect.

4. Revised Rulemaking Timeline: Now Targeting Q1 2026

CARB originally planned to release formal rules for SB 253 and SB 261 in October 2025 with a Board hearing before year-end. However, due to the high volume of stakeholder feedback and continued work to identify the range of covered entities, CARB has postponed the initial rulemaking to Q1 2026.

The forthcoming rule package will address:

• The definition of “doing business in California”

• Reporting fees and due dates

• Scoping definitions and boundaries

• Additional procedural requirements for emissions assurance and public disclosure

This delay gives companies a bit more time to prepare — but the original statutory deadlines remain unchanged.

5. What Companies Should Do Now

1. Map your GHG data to CARB’s template.
Even if your company doesn’t plan to submit via the Excel file, the structure provides a reliable preview of what CARB will expect.

2. Engage assurance providers early.
Limited assurance for Scope 1 and 2 data is required under SB 253 — start contracting auditors now to ensure capacity.

3. Cross-check your climate-risk reporting framework.
Ensure your upcoming SB 261 disclosures align with CARB’s checklist and recognized frameworks (TCFD/ISSB).

4. Verify your inclusion on CARB’s preliminary entity list.
Submit corrections or feedback through the voluntary survey to avoid surprises in 2026.

5. Stay tuned for Q1 2026 rulemaking.
Expect additional clarity on reporting fees, definitions, and submission platforms early next year.

Bottom Line

California’s climate-disclosure regime is taking shape fast. With CARB’s draft templates, checklists, and extended rulemaking timeline, companies now have a clearer view of what’s coming — and a short window to align systems, secure verifiers, and engage with regulators before requirements lock in.