While the SEC’s climate disclosure rules remain bogged down in a litigation quagmire, the California Air Resources Board (CARB) continues its efforts to implement California’s own climate disclosure regime (even though those requirements are also the subject of ongoing litigation). Last month, CARB released a preliminary list of over 3,100 companies that could be subject to upcoming reporting requirements under either SB 253 or SB 261.

Last Friday, CARB released a draft reporting template for those companies that will be required to report their Scope 1 and Scope 2 emissions under SB 253 beginning next year. The draft template states:

The template is intended to streamline reporting, especially for entities disclosing GHG emissions for the very first time. Reporting entities are not currently required to use the template; its use is voluntary for the 2026 reporting cycle. CARB will provide guidance on later reporting cycles as part of its regulatory process. CARB is seeking input on this draft template to help CARB further refine the template.

CARB invites reporting entities and other stakeholders to review the draft template and provide feedback on its structure, substance, and alignment with SB 253’s overarching objectives.

The template is organized into the following sections:

– Organization Information
– Third-Party Verification
– Inventory Boundary
– Scope 1 and Scope 2 Disclosure
– Methodology
– De Minimis / Minor Sources
– California MRR Fields (if applicable)
– Emission Reductions (if applicable)

The template also includes optional fields for future reporting years as CARB further develops the program. These optional fields include base year emissions to support intraorganizational comparison, providing more transparency to investors and stakeholders.

CARB is seeking comments on the draft reporting template, either through the public docket that will remain open through October 27, 2025, or by email to climatedisclosure@arb.ca.gov.

– Dave Lynn