California climate disclosure laws: CARB releases optional intake platform and guidance for 2026 reporting
5 min read
On September 1, 2026, pursuant to California's Climate Corporate Data Accountability Act ("SB 253"), the California Air Resources Board ("CARB") issued Guidance for SB 253 2026 Reporting Submittals (the "Guidance") and opened an optional online intake platform for submitting Scope 1 and Scope 2 greenhouse gas ("GHG") emissions reports and statements of non-reporting for the November 10, 2026 deadline1 (the "Optional Intake Platform"). CARB also released an instructional video that walks users through the Optional Intake Platform submission process. These materials primarily address the procedural aspects of (i) how SB 253 reports or statements of non-reporting may be submitted and (ii) billing information for fee invoicing.
SB 253's companion law, SB 261, remains on hold pending litigation. SB 253 is also being challenged in the same litigation, however, SB 253 remains in effect.
Key takeaways
- What and How to Submit. Companies that are submitting SB 253 reports or statements of non-reporting can use the Optional Intake Platform or comply by emailing the submissions to climatedisclosure@arb.ca.gov. Submissions should be made before the November 10, 2026 deadline. Entities may submit (i) emissions data using CARB’s Draft Scope 1 & 2 GHG Reporting Template, found on CARB's website here, (ii) "an existing annual report" that includes Scope 1 and 2 greenhouse gas emissions data, (iii) existing Scope 1 and 2 GHG emissions data reported to other programs or voluntary initiatives or (iv) a statement of non-reporting, in each case, which should be submitted via the Optional Intake Platform or via email to CARB. Any billing information entered into the Optional Intake Platform will not be made public; however, SB 253 reports and statements of non-reporting that are submitted via the Optional Intake Platform will be made public. The Optional Intake Platform requires information be submitted for each individual covered entity (not just a parent entity).
- Enforcement Discretion / Statements of Non-Reporting. The Guidance states that CARB will use exercise enforcement discretion for the "first report due in 2026…allowing reporting entities to submit Scope 1 and Scope 2 emissions for their prior fiscal year based on information they already have or were collecting when the December 2024 Notice was issued, whether or not the data received limited assurance." CARB emphasized in the Enforcement Notice that it will "exercise enforcement discretion for the first reporting cycle, on the condition that entities demonstrate good faith efforts to comply with the requirements of the law." CARB also reiterates in the Guidance that entities that were not collecting data or were not planning to collect data at the time the Enforcement Notice was issued, i.e., December 5, 2024, are not expected to submit Scope 1 and 2 reporting data for this first reporting cycle in 2026. CARB requests that such entities submit a statement of non-reporting (on company letterhead) indicating that they were not collecting data and were not planning to collect data at the time the Enforcement Notice was issued.
- Assurance. The Guidance states that while SB 253 "requires limited assurance beginning in 2026…CARB will accept submissions whether or not assurance has been obtained for the 2026 cycle."2 CARB has stated in public workshops and its most recent FAQ document that, for the first reporting deadline of 2026, CARB is not requiring any assurance for the initial Scope 1 and 2 disclosures, but if companies have such assurance they can submit it. Beginning with reports submitted in 2027, entities must obtain a limited assurance engagement (including a written report from an independent third party provider) for its Scope 1 and 2 GHG emissions, including biogenic emissions.3
- Scope 2 Emissions Factors. Reporting entities may use the most recent official U.S. EPA eGRID release (eGRID 2023) or, if preferable, the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative. Companies may also elect to use alternative credible emission factor sources and are encouraged to identify the emission factors used and their sources.
Optional Data. The Optional Intake Platform has a section that allows entities to submit optional data (not required to be reported for 2026). The Guidance states that "CARB encourages reporting entities to provide additional details in the first year of reporting, where available. These details can help qualify the reported emission numbers and provide important context. Such details can include, but are not limited to, descriptions of methodologies, data sources, global warming potential values, emission factors, organizational boundaries, disaggregated emission data by category and gas, and any assumptions used. Reporting entities may refer to CARB's draft reporting template for examples of questions connected to this type of information."
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 announces Scope 3 phase in, rescinds exemption for insurers and codifies 2026 enforcement discretion,' 'California climate disclosure laws: CARB delays SB 253 reporting deadline to November 10,' [ML1.1]'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.'
1 CARB's draft California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation codifying the November 10, 2026 deadline is pending approval from the California Office of Administrative Law. See our alert on the regulation and related developments, here.
2 SB 253 states that "assurance engagement for scope 1 emissions and scope 2 emissions shall be performed at a limited assurance level beginning in 2026 and at a reasonable assurance level beginning in 2030." See California Health and Safety Code § 38532(c)(2)(F)(ii).
3 The limited assurance engagement for reports submitted in 2027 must be conducted in full conformance with one of the following standards: (1) AA1000 Assurance Standard (AA1000AS v3); (2) American Institute of Certified Public Accountants (AICPA AT-C Section 210); (3) International Standard on Assurance Engagements (ISAE) 3410 applied in conjunction with ISAE 3000 (Revised), for engagements commencing prior to December 15, 2026; (4) International Standard on Sustainability Assurance (ISSA) 5000 for engagements commencing on or after December 15, 2026; or (5) International Organization for Standardization (ISO) 14064-3:2019 (with additional accreditation requirements). A reasonable assurance engagement may substitute for limited assurance.
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