CARB Delays Climate Disclosure Rulemaking, but Reporting Deadlines Remain

The California Air Resources Board (CARB) has adjusted its timeline for developing climate disclosure rules under Senate Bill (SB) 253 and Senate Bill (SB) 261. While the agency takes more time to finalize guidance, the reporting deadlines for covered companies remain unchanged.

SB 253 and SB 261 Overview

SB 253 applies to companies with more than $1 billion in annual revenue that “do business in California.” It requires disclosure of greenhouse gas (GHG) emissions, beginning with Scopes 1 and 2 in 2026, followed by Scope 3 in 2027. The disclosures must follow recognized GHG accounting standards and will eventually require independent assurance (CARB Program Page). The first disclosures for Scope 1 and 2 emissions are due June 30, 2026.

SB 261 applies to companies with more than $500 million in annual revenue and requires biennial reports describing their climate-related financial risks and mitigation measures. These reports are expected to align closely with the Task Force on Climate-Related Financial Disclosures (TCFD) framework. The first reports are due January 1, 2026.

Together, these two laws form the foundation of California’s climate disclosure framework, aiming to provide investors and the public with consistent and comparable information on corporate climate risks and impacts.

A Shift in the Rulemaking Timeline

In early October 2025, CARB announced that it would extend its rulemaking schedule for the state’s climate disclosure laws, SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Disclosure Act), into the first quarter of 2026. CARB explained that the extension allows more time to review public comments and refine key definitions and reporting processes. The agency has emphasized its goal of ensuring that the final regulations are clear and workable for companies of different sizes and industries.

While this adjustment gives CARB additional time to develop detailed rules, it does not alter the statutory deadlines for company reporting under the two laws. Organizations subject to SB 253 or SB 261 should continue preparing for their upcoming disclosure obligations.

The reporting deadlines established by statute remain in place:

SB 261: First climate risk report due January 1, 2026
SB 253: First GHG emissions report (Scopes 1 and 2) due June 30, 2026, with Scope 3 disclosures beginning in 2027

CARB has indicated it may apply enforcement discretion during the initial reporting cycle if companies demonstrate good-faith compliance efforts. However, the legal obligations remain intact.

What This Means for Businesses

The timeline change gives CARB more flexibility but does not extend this flexibility to companies. Because the statutory deadlines have not shifted, organizations should continue planning and collecting data even as they wait for final guidance.

Despite these delays, experts agree that early preparation is the best strategy. Companies can start mapping emissions data, evaluating climate-related financial risks, and aligning their internal processes with the GHG Protocol and TCFD standards.

Steps to Prepare Now

Starting early can reduce compliance risk, improve data quality, and demonstrate a good-faith approach once reporting begins. We recommend taking the following steps:

Confirm applicability. Review your operations and revenue structure to determine whether your company falls within the scope of SB 253 or SB 261.
Start data collection. Gather GHG emissions data for fiscal year 2025 and identify any gaps in Scope 3 data availability.
Align with existing frameworks. Use the GHG Protocol and TCFD as references, since CARB has signaled that its rules will rely on these standards.
Engage stakeholders. Coordinate sustainability, finance, and legal teams to establish governance around disclosure.
Monitor updates. Follow CARB’s official program page and workshops for the latest information.

How Antea Group Can Help

At Antea Group, we recognize that the delay in CARB’s rulemaking creates uncertainty for companies that still need to meet near-term deadlines. Our recommendation is that clients move forward with SB 261 reporting by January 1, 2026, even if that means including omission statements where specific data or methodologies are not yet available. Submitting an initial report demonstrates good-faith compliance and provides a foundation to build on once the final CARB guidance is published.

Antea Group can support your organization in two critical ways:

Report preparation and disclosure support. Our consultants can help you develop and document your first climate risk disclosure under SB 261 or your initial emissions report under SB 253. We guide clients in identifying reportable data, framing omission statements appropriately, and ensuring alignment with TCFD and GHG Protocol expectations.
Full climate risk assessment with scenario analysis. After the initial filing, we can conduct a comprehensive climate risk assessment that includes scenario analysis and quantitative evaluation of transition and physical risks. These insights allow us to help you produce a complete, CARB-ready report once the final rulemaking is complete.

By acting now, companies can demonstrate transparency, manage compliance risk, and position themselves for a smoother transition when CARB’s final regulations take effect.

To learn more about our CARB disclosure support services or to begin preparing your SB 253 or SB 261 report, please visit Antea Group’s Sustainability Homepage.

In Summary

CARB’s extended rulemaking schedule reflects an effort to develop thoughtful and practical regulations. However, the reporting requirements under SB 253 and SB 261 are still on schedule. Companies that act now to collect data and organize governance will be best prepared once the final rules are adopted.

The rulemaking may take longer, but the time to prepare is now.

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