On September 24, the California Air Resources Board (CARB) published its preliminary list of companies it believes may be covered under California’s new climate disclosure requirements: Senate Bill (SB) 253, the Climate Corporate Data Accountability Act, and SB 261, the Climate-Related Financial Risk Act.

Coverage depends on two criteria:

• Revenue threshold: over $500 million for SB 261; over $1 billion for SB 253

• Doing business in California: a broad test that captures most companies with sales, operations, or a legal presence in the state

CARB is clear that this list is not exhaustive. Companies are responsible for compliance even if they are not named. Many businesses that meet the thresholds are likely missing from this first determination.

Immediate Actions for Companies

Confirm Your Status - Review corporate structure, revenue, and California operations with legal counsel to determine if you fall within scope.

Mobilize Internal Teams - Bring together finance, operations, procurement, IT, and sustainability to align on data collection, ownership, and deadlines.

Plan for Phased Compliance

• SB 261: Biennial climate risk reports begin January 1, 2026

• SB 253: Scope 1–2 emissions (with limited assurance) due June 30, 2026; Scope 3 emissions reporting begins in 2027

Prepare for Assurance - Limited assurance is required with the first SB 253 filing. Early planning reduces risk of reporting gaps, reputational damage, or penalties. (SB 261 does not require assurance.)

Bottom Line

California’s disclosure laws are among the most ambitious in the U.S. and will set a precedent for state-level climate reporting. Even if your company is not named on CARB’s preliminary list, if you meet the thresholds and do business in California, now is the time to act.