California Delays First Corporate Climate Reporting Deadline as CARB Revises Disclosure Rules

Key Takeaways

• Reporting Deadline Extended: CARB plans to move the first Scope 1 and Scope 2 greenhouse gas reporting deadline from August 10 to November 10, 2026, giving companies an additional three months to prepare.
• Regulation Returned for Clarification: The agency has withdrawn its regulatory package from final review to make limited clarifying changes before resubmitting it to the Office of Administrative Law.
• Public Comment to Resume: The proposed revisions will be released as part of a forthcoming 15-day public comment period before the regulation proceeds toward final approval.
• SB 253 Timeline Remains Intact: The extension does not alter California's broader greenhouse gas disclosure requirements, with Scope 3 emissions reporting still scheduled to begin in 2027 for covered companies.
• Large Companies Remain in Scope: The reporting regime continues to apply to U.S.-based companies with more than $1 billion in annual revenue that do business in California.

Deep Dive

California has given large companies something they rarely receive in the climate reporting world—time. Not much of it (three months) but enough to acknowledge a reality that had become increasingly difficult to ignore. Rules are easier to follow when they have stopped changing.

The California Air Resources Board announced this week that it will postpone the state's first deadline for reporting Scope 1 and Scope 2 greenhouse gas emissions from August 10, 2026, to November 10, 2026. The extension is tied directly to the regulation itself, which remains unfinished. Rather than continue the approval process, CARB has withdrawn the package it submitted to the Office of Administrative Law, choosing instead to make what it describes as limited revisions that clarify certain requirements before asking regulators for final approval.

That distinction matters. The delay is not a retreat from California's climate disclosure regime, nor does it suggest the state is reconsidering the obligations created by Senate Bill 253. It reflects something more prosaic, and perhaps more consequential for the companies expected to comply: the recognition that the first year of any reporting system depends as much on clarity as on ambition. Compliance deadlines have a way of hardening uncertainty into risk when the rules beneath them are still being refined.

CARB now intends to release those revisions during a forthcoming 15-day public comment period before resubmitting the regulation to the Office of Administrative Law. Because that additional step may push back final approval, the agency concluded that the reporting deadline should move with it, giving companies an opportunity to work from a settled rulebook rather than one that is still being annotated.

The regulation traces back to February 26, when the Air Resources Board approved what it calls the Initial Regulation, establishing both the program's fee structure and its inaugural reporting timetable under California Health and Safety Code Section 38532. Approval by the Board, however, was never the final act. The regulation must still receive approval from the Office of Administrative Law before it can take effect as part of Title 17 of the California Code of Regulations, and it is that final stretch of the process that has now been interrupted.

CARB has been careful to characterize the forthcoming amendments as clarifications rather than substantive rewrites, a signal that the architecture of the program remains intact even as some of its finer points are being adjusted. The agency has also continued releasing guidance and other resources intended to help companies prepare their 2026 emissions reports, suggesting that the implementation work has not paused simply because the legal text has taken one more trip through the rulemaking process.

For many companies, that practical work is already well underway. Senate Bill 253 applies to U.S.-based businesses with more than $1 billion in annual revenue that conduct business in California, requiring annual disclosure of greenhouse gas emissions from the previous fiscal year. The first reporting cycle, due in 2026, covers only Scope 1 and Scope 2 emissions. That comparatively narrow beginning will not last long. Starting with reports due in 2027, companies must also disclose Scope 3 emissions, extending the reporting obligation beyond facilities and purchased energy into the far less tidy world of suppliers, logistics, customers, and the rest of the value chain where emissions often become both larger and more difficult to measure.

The three-month extension does not change that trajectory. It simply acknowledges that before regulators can expect companies to produce comparable disclosures, they first owe them a regulation whose meaning no longer depends on what might still change tomorrow.

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