Legal ESG

Legal ESG

California CARB Defers SB 253 Scope 1/2 Reporting Deadline to November 10

BY INSIDE PRACTICE · SEPTEMBER 4, 2026 · 1 MIN READ

In a significant late-stage adjustment, California's Air Resources Board announced on June 24, 2026 that it was deferring the first-year Scope 1 and Scope 2 greenhouse gas reporting deadline under SB 253 (Climate Corporate Data Accountability Act) from August 10, 2026 to November 10 — a three-month extension. The deferral follows CARB's July 21 public workshop on SB 253 implementation and reflects continued rulemaking complexity; a Ninth Circuit temporary injunction issued in November 2025 had already created uncertainty around the regulatory timeline. In-scope entities — US-based companies doing business in California with more than $1 billion in annual revenue — now have until November 10 to submit their initial Scope 1 and Scope 2 reports, with Scope 3 obligations following in 2027. No third-party assurance is required for the initial report cycle. For multinational companies and their outside counsel, California remains the operative US climate disclosure regime with real teeth, even as the SEC retreat removes federal pressure.

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