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Earlier this month, the California Office of Administrative Law approved CARB’s initial regulations implementing the greenhouse gas emissions reporting and climate-related financial risk disclosure laws. As Zach recently noted on the PracticalESG blog, companies will now have until November 10, 2026 to submit reports covering their Scope 1 and 2 emissions. The blog includes this passage from a Morgan Lewis memo:

The California Office of Administrative Law approved the California Air Resources Board’s initial regulations implementing the state’s corporate greenhouse gas emissions reporting and climate-related financial risk disclosure laws on October 12, making the regulations immediately effective. The approval completes the administrative review process and formally establishes November 10, 2026 as the first-year reporting deadline under Senate Bill 253. Covered companies are subject to the initial Scope 1 and Scope 2 emissions reporting requirements by that date, consistent with CARB’s first-year reporting guidance.

Zach also notes:

California regulators have indicated that first-year reporting will be lightly scrutinized. The California Air Resources Board (CARB) is looking for companies to make good-faith efforts to comply. Alternatively, 2027 may be a different story. CARB has indicated that new reporting rules are coming. 2027’s rules are expected to introduce more stringent requirements, which will bolster reporting quality and increase compliance complexity.

SB 253’s companion law, SB 261, will require climate-related financial disclosures in addition to GHG metrics. SB 261 is currently enjoined by the Ninth Circuit Court of Appeals. The Court’s Opinion is still pending after oral arguments were heard over ten months ago. SB 261 reporting was originally slated to begin alongside SB 253, meaning that 2027 could see SB 261’s requirements reintroduced depending on litigation timelines and outcomes.

At the federal level, the SEC has not yet taken any action on its proposed rescission of the agency’s climate disclosure rules. Earlier this month, certain members of the House Financial Services Committee submitted a letter to the Commission expressing strong opposition to the SEC’s proposal.

– Dave Lynn