California confirms November 10 deadline for first SB 253 emissions reports
On October 12, the California Office of Administrative Law approved CARB’s initial regulation implementing SB 253 and SB 261, and the regulation became effective the same day, according to an October 14 Sullivan & Cromwell analysis.
Inside Practice · OCTOBER 16, 2026 · 1 MIN READ
On October 12, the California Office of Administrative Law approved CARB’s initial regulation implementing SB 253 and SB 261, and the regulation became effective the same day, according to an October 14 Sullivan & Cromwell analysis. The rule fixes November 10, 2026 as the first deadline for SB 253 Scope 1 and Scope 2 emissions reports, codifies first-year relief, sets a common applicability framework and establishes annual fees; SB 261 enforcement remains paused by a Ninth Circuit injunction. Companies should now convert scoping conclusions into signed reporting, recordkeeping and submission controls rather than wait for the later rulemaking on Scope 3 emissions and assurance. Counsel should also separate the live SB 253 obligation from the enjoined SB 261 program so that litigation uncertainty in one regime does not delay compliance with the other.