California SB 253: Scope 1 and Scope 2 GHG Reporting Deadline Moved to November 10, 2026 — $1B+ Revenue Threshold; No Assurance Required for Year One

CARB's June 24 announcement reset the California Climate Corporate Data Accountability Act (SB 253) first-year reporting deadline from August 10 to November 10, 2026, after withdrawing its current rulemaking text and announcing a forthcoming revised regulation with a 15-day comment period. The November 10 deadline is the operative hard date for corporate counsel; it applies to all business entities with more than $1 billion in total global annual revenue (determined by the lesser of the two prior fiscal years) that do business in California — defined by sales exceeding approximately $757,070 in California for 2025, with no payroll or property threshold. Scope 3 reporting remains deferred to 2027. For the first year: (1) limited assurance is not required; (2) CARB will exercise enforcement discretion for entities making a good-faith effort; (3) companies that were not collecting Scope 1 and Scope 2 data as of December 2024 must submit a statement on company letterhead confirming the gap — they are not required to generate data retroactively. Davis Polk estimated annual compliance costs at approximately $82,000 for Scope 1 and 2 reporting alone, rising to $135,000–$152,000 per entity per year once limited assurance and Scope 3 are phased in. SB 261 — the climate financial risk disclosure requirement — remains enjoined by the Ninth Circuit; oral arguments were heard January 9, 2026, with no ruling issued. For in-house sustainability counsel: the November 10 deadline affects both public and private companies; it is often overlooked that private US and non-US businesses above the revenue threshold are in scope if they have California nexus. Companies that have not started Scope 1 and 2 data collection should submit the letterhead exemption statement; those that have been collecting data should file. The 2027 Scope 3 requirement is approaching quickly and supplier engagement is best begun now.