On November 18, 2025, the California Air Resources Board (CARB) hosted its latest public workshop on the state’s Climate Disclosure Laws - SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk). Shortly after the CARB workshop began, the Ninth Circuit Court of Appeals issued an order temporarily pausing enforcement of SB 261 while the Court reviews the ongoing appeal.
Below, we outline major takeaways from the latest CARB updates and several actions companies may want to consider during this period of uncertainty.
CARB Updates to SB 261 (Climate-Related Financial Risk)
Despite ongoing legal challenges, CARB confirmed that SB 261 deadlines remain unchanged, and companies should continue preparing for compliance. Key updates include:
- Statutory Deadline: Reports must be posted on company websites by January 1, 2026, regardless of the temporary enforcement pause.
- Public Docket: CARB will open the docket on December 1, 2025. Companies must submit a link to their published report by July 1, 2026.
- Reporting Frameworks: Reports must follow TCFD, IFRS, or another permitted framework. Companies may disclose gaps, limitations, and assumptions used in assessing climate-related risks.
CARB Updates to SB 253 (Scope 1 & 2 GHG Emissions Disclosure)
CARB clarified several important points regarding SB 253 during the November 2025 workshop. While SB 261 faces legal uncertainty, SB 253 remains unaffected, and companies should continue preparing for compliance. Key updates include:
- No Impact from SB 261 Injunction: SB 253 requirements remain in force.
- First-Year Reporting Deadline: CARB proposed a one-time deadline of August 10, 2026, for Scope 1 and Scope 2 emissions reporting.
- Assurance Requirements: Limited assurance is not required in 2026, but companies should provide the best available data and begin preparing for mandatory assurance in subsequent years.
- Report Submission Options: Companies may submit existing GHG reports, and CARB’s draft template is optional.
- Alternative for Non-Reporting Entities: Organizations that were not collecting or planning to collect GHG data when CARB issued its Enforcement Notice in December 2024 may submit a statement letter instead of emissions data for 2026.
Additional updates from the November 2025 CARB workshop
Revenue Applicability
CARB confirmed that revenue thresholds for SB 253 and SB 261 compliance will be based on the lesser of the entity’s two previous fiscal years of revenue. This clarification is critical for organizations near the $500 million or $1 billion thresholds, as it may affect applicability and reporting obligations.
Proposed Exemptions
CARB outlined potential exemptions to reduce compliance burdens for certain entities:
- Non-profit and charitable organizations may be excluded from reporting requirements.
- Businesses whose only California presence is teleworking employees could also qualify for exemption.
These proposals are not yet finalized, so companies should continue monitoring CARB’s updates
Future Rulemaking Under SB 253
CARB signaled that subsequent rulemaking for SB 253 will establish additional program requirements beyond 2026, including:
- Assurance requirements for greenhouse gas disclosures.
- Recurring reporting deadlines for future years.
- Standardized report templates to improve consistency.
- Enforcement provisions detailing penalties for non-compliance.
How Companies Can Prepare for California Climate Disclosure Laws
Confirm Your Applicability
Each company should assess and confirm its applicability under SB253 and SB261, given the latest clarification on revenue, doing business, and parent-subsidiary rules, rather than relying on the preliminary in-scope list.
Strengthen Internal Data Collection
Strengthen internal data collection processes for Scope 1 and Scope 2. Even without a 2026 assurance requirement, companies should begin tightening data governance, documentation, and evidence trails now. Building or refining these processes takes time, often requiring coordination across teams. Starting early will help streamline future verification when assurance becomes mandatory.
Prepare for Assurance—Even If It’s Not Required Yet
Consider pre-assurance readiness or a limited assurance review. Early verification can surface data gaps, inconsistencies, and documentation issues. Even if companies choose not to pursue full assurance at this time, they should prepare data as if it will be verified, including maintaining clear evidence files, audit trails, and formal calculation methodologies.
Engage Experienced Third-Party Support
Consider engaging a third-party to conduct a pre-assurance review to build confidence in your emissions reporting systems before mandatory requirements take effect. These reviews can help identify gaps, inconsistencies, and documentation issues early, reducing compliance risk. Third-party consultants also bring strategic value in today’s sustainability-focused business environment. They can quickly pinpoint high-emitting suppliers and uncover opportunities to improve efficiency and reduce costs—turning compliance into a competitive advantage.
Firms like Cameron-Cole, an ADEC Innovation, have the expertise and experience to guide organizations of all sizes toward climate-focused compliance while helping them achieve broader sustainability goals.
For more than 25 years, Cameron-Cole has provided GHG reporting and verification services for clients ranging from small municipalities to the world's largest corporations. We were among the first organizations in the United States to provide GHG verification services and continue to be one of the most active verification bodies in the country. Contact us to learn more about our services and how we can help you stay ahead of mandatory reporting deadlines and changing guidance.
This blog provides general information and does not constitute the rendering of legal, economic, business, or other professional services or advice. Consult with your advisors regarding the applicability of this content to your specific circumstances.
