Client Alert: CARB Delays Climate-Disclosure Rulemaking Timeline to Q1 2026

CARB previously indicated that it planned to issue its Notice of Proposed Rulemaking (NPR) on October 14, 2025, a key step in the regulatory process for SB 253 and SB 261. That date has now passed without a proposed rulemaking package being released, and CARB has since provided additional context on the revised timing. 

Following its August 2025 public workshop, CARB published several new resources to solicit feedback, including: 

In an October notice, CARB acknowledged the large volume of stakeholder feedback received and stated that it is proposing an updated timeline to bring the initial rulemaking, including fee-related provisions, to the Board in Q1 2026. 

CARB remains in the pre-rulemaking phase, continuing to gather input ahead of issuing the formal regulatory package. 

What Does This Mean for Regulated Companies?

The statutory reporting deadlines remain unchanged. 

  • SB 261 climate-risk disclosures are still due January 1, 2026. CARB’s public docket for posting reports is scheduled to open in December 2025 and remain open through July 2026. 

  • SB 253 emissions reporting continues to be based on FY 2025 data for Scope 1 and Scope 2, with Scope 3 reporting to follow using FY 2026 data. 

CARB has emphasized that it will exercise enforcement discretion in the first reporting year for companies that make good-faith efforts to comply with the regulations. This approach does not alter reporting deadlines or filing requirements. 

The New Development: Voluntary SB 253 Template 

The most substantive recent update is CARB’s release of a voluntary SB 253 Scope 1 and Scope 2 GHG Reporting Template on October 10, 2025.

This template provides a practical starting point for companies preparing their emissions inventories and offers insight into the format CARB expects for Scope 1 and Scope 2 disclosures. While use of the template is voluntary, it may help demonstrate a good-faith compliance effort during the first reporting cycle. 

Why Companies Should Stay Focused 

CARB’s proposed shift to bring the rulemaking package to the Board in Q1 2026 does not change any reporting obligations. The current statutory deadlines remain in place, and no new guidance has been issued altering those dates. 

Companies should: 

  • Continue preparing for the original reporting schedule 

  • Review and, where appropriate, use CARB’s voluntary template 

  • Provide feedback through CARB’s public docket (open through October 27, 2025) and the covered-entity survey 

  • Monitor for CARB’s forthcoming Notice of Proposed Rulemaking, expected in early 2026 

Key Takeaway 

CARB did not issue its expected proposed rulemaking package on October 14, but the agency has since clarified that it plans to bring the initial rulemaking to the Board in Q1 2026. This timing adjustment does not affect statutory reporting deadlines. The release of CARB’s voluntary Scope 1 and Scope 2 template remains the most significant recent development and provides companies with a useful tool to prepare for compliance under SB 253. 


For questions regarding SB 253 & SB 261 contact:

Nick McCreary, MS, LEED AP BD+C
Senior Vice President, Sustainability
KERAMIDA Inc.

Email Nick at nmccreary@keramida.com

Xuqing Xiong, M.S., P.E.
Vice President of GHG Services
KERAMIDA Inc.

Email Xuqing at xxiong@keramida.com

Faythe Missick, MA, MSc
Senior Manager, Sustainability
KERAMIDA Inc.

Email Faythe at fmissick@keramida.com