California climate disclosure laws: CARB delays SB 253 reporting deadline to November 10

On June 24, 2026, the California Air Resources Board ("CARB") announced that it is updating its regulatory proposal for the Climate Corporate Data Accountability Act (SB 253) to defer the initial reporting deadline for Scope 1 and Scope 2 greenhouse gas emissions by three months—from August 10 to November 10, 2026. CARB intends to revise its proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation implementing SB 253 and the Climate-Related Financial Risk Act (SB 261) (the "Regulation").¹ If the new, revised Regulation gets approved by the California Office of Administrative Law ("OAL"), in-scope entities will be required to comply with the new November 10, 2026 deadline.²

SB 253's companion law, SB 261, remains on hold pending litigation.³ SB 253 is also being challenged in the same litigation, however, SB 253 remains in effect.

Key takeaways

• At this time, it's unclear what changes CARB will make to the Regulation. The revised regulatory text and the formal notice opening the comment period have not yet been published. In its announcement, CARB stated that it will be proposing "limited changes to the [Regulation] to clarify certain requirements." The changes will be subject to a forthcoming 15-day public comment period. The Scope 1 and 2 emissions disclosures deadline extension will give reporting entities "additional time" following the expected, future adoption of the Regulation.
• Insurance Industry Exemption. On February 26, 2026, during a public hearing (the "February Hearing"), CARB approved the Regulation with one exception: that CARB's staff engage with the California Department of Insurance ("CDI") to confirm that, under existing CDI requirements, insurance companies must disclose the emissions data that is required under SB 253 – and if they are not, such companies must be required to submit such emissions data under SB 253 / the Regulation.⁴ It's possible that CARB could make changes to the Regulation relating to the insurance industry.
• Enforcement Discretion. CARB has issued numerous verbal and written statements indicating that it will use enforcement discretion "for good-faith first-year submissions."⁵ The Regulation contains the August 10, 2026 deadline for Scope 1 and 2 emissions disclosures and is silent with respect to CARB’s stated enforcement discretion policy. CARB's statements on its planned enforcement discretion have varied in terms of what exactly CARB wants companies to submit for the first reporting deadline, creating uncertainty for in-scope entities.⁶ CARB has communicated (e.g., in their staff report and in their updated FAQs) that entities that were not collecting emissions data (or were not planning to collect such data) as of the date of CARB's Enforcement Notice (i.e., December 5, 2024) are not expected to submit Scope 1 and 2 data in 2026. CARB indicates that such entities should submit a statement on company letterhead to CARB stating that they did not submit a report and that the company was not collecting data or planning to collect data at the time the Enforcement Notice was issued.⁷ Some speakers at the February Hearing urged CARB to include in the Regulation clarification on this informal exemption for companies that were not collecting data as of December 5, 2024; one speaker noted that there is a "gray area" regarding these matters since the Regulation includes a firm August 10, 2026 deadline for all entities. It's possible that CARB could make changes to the Regulation relating to its enforcement discretion for the first reporting deadline.
• Given CARB's stated intention of making "limited changes… to clarify certain requirements," CARB likely will not be introducing new, substantive requirements.
• CARB has stated that it will be releasing additional rulemaking "later this year" to cover additional SB 253 requirements, including requirements for 2027 and beyond, Scope 3 emissions, and data assurance requirements. We expect these topics to not be covered in the expected changes to the Regulation, but rather in a separate rulemaking later this year.

_{1 SB 253 and SB 261 were amended and consolidated into Senate Bill 219: Greenhouse gases: climate corporate accountability: climate-related financial risk.
2 CARB submitted the Regulation to the OAL on May 20, 2026. On June 24, 2026, CARB indicated that the Regulation and associated rulemaking documents submitted to OAL for final review and approval have been withdrawn and will be resubmitted (after changes are made that will be subject to the 15-day public comment period).
3 On November 18th, 2025, the Ninth Circuit granted a motion for injunction on SB 261 prohibiting CARB from enforcing SB 261 pending the appeal period.
4 At the hearing, there was significant discussion regarding whether insurance companies should be subject to SB 253 and the Regulation. In contrast to SB 261, the statutory language of SB 253 does not expressly carve-out insurance companies. However, CARB's existing Regulation exempts insurance companies from both SB 261 and SB 253.
5 See CARB's press release following the February hearing.
6 Some of CARB's statements have indicated that in-scope entities that "were not planning on collecting data" as of December 5, 2024 do not have to submit data, while other statements have not indicated that. Since SB 253 was signed into law in October 2023, most in-scope entities that were aware of the law would have been "planning on collecting data" as of December 5, 2024. During the February Hearing, CARB stated that they want companies to provide to CARB by the August 10, 2026 deadline "whatever they were collecting" as of December 5, 2024 and if companies weren't collecting any data, they should let CARB know that and also let CARB know "what their plan is" to collect data going forward, so that CARB can confirm that a "good faith effort is being made". Notably, in other statements by CARB on what companies should report if they were not collecting data on December 5, 2024, CARB did not indicate that such companies should report "whatever they were collecting" and/or "what their plan is."
7 CARB has stated that it will open a public docket near the first year 2026 reporting deadline, which will include these statements.}

This article is part of a series on the California climate disclosure laws. For more information, see our previous articles: 'California climate disclosure laws: CARB approves greenhouse gas reporting and climate financial risk disclosure regulation,' 'California climate disclosure laws: Ninth Circuit hears oral argument; no ruling yet,' 'California Climate Disclosure Laws: CARB issues draft regulations,' 'California Climate Disclosure Laws: Ninth Circuit temporarily halts SB 261 and CARB provides new guidance', 'California Climate Disclosure Laws: CARB delays regulations, releases Scope 1 and 2 template, and list of covered entities,' 'California Climate Disclosure Laws: CARB releases draft guidance on SB 261,' 'California Climate Disclosure Laws: CARB Refines Applicability, Deadlines, and Scope,' 'California Climate Disclosure Laws: CARB Affirms Reporting Deadlines, but Delays Regulations that Would Clarify Applicability,' and 'California Bills to Require Greenhouse Gas Emissions Reporting From Companies Doing Business in the State.'

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_{This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.}

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