Client Alert: Latest Key Developments for SB 253 

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July 2026 updates including SB 253 reporting deadlines, the 2027 Scope 3 category phase-in, and insurance company reporting requirements. 

During the July 21, 2026 workshop, CARB provided updates on the 2026 initial regulation as well as updates to proposed rulemaking concepts for 2027. Below is a summary of the most important developments: 

Updated 2026 Reporting Deadline 

  • CARB's Final Package for the initial regulation, submitted to the Office of Administrative Law (OAL) on May 20, 2026, was withdrawn to allow for limited clarifying changes before resubmission. 

  • CARB proposed new 2026 reporting deadline for Scope 1 and Scope 2 GHG emissions from August 10, 2026 to November 10, 2026. 

  • Additional 2026 reporting guidance, including a voluntary online intake platform, guidance document, and instructional video, is expected by September 1, 2026. 

Proposed General Reporting Requirements aligned with GHG Protocol 

  • SB 253 directs reporting entities to disclose GHG emissions in conformance with the Greenhouse Gas Protocol  

  • CARB proposes General Reporting Requirements aligned with the GHG Protocol including quantification methodologies, measurement uncertainty, missing data protocols, biogenic emissions, voluntary emissions reductions or removals, data exclusions, methodology changes, and previous year recalculations. 

Proposed Scope 2 Reporting Requirements 

  • Scope 2 GHG emissions will be disclosed in accordance with the existing GHG Protocol Scope 2 Guidance (2015), which includes both location-based and market-based methods. 

  • Scope 2 GHG emissions shall be expressed in metric tons of CO2 equivalent by source type, including electricity, steam, heating, and cooling emissions. 

  • Additionally, Scope 2 GHG emissions shall be expressed in metric tons of the following GHGs in CO2 equivalent: CO2, CH4, N2O, HFCs, PFCs, SF6, and NF3. 

Proposed Scope 3 Reporting – Category Phase-In 

  • CARB's March workshop introduced three potential pathways for Scope 3 reporting. At the July 21 workshop, CARB proposes requiring only the five most commonly reported Scope 3 categories starting in 2027: 

  • Category 1 (Purchased Goods and Services) 

  • Category 3 (Fuel- and Energy-Related Activities) 

  • Category 5 (Waste Generated in Operations) 

  • Category 6 (Business Travel) 

  • Category 7 (Employee Commuting) 

  • Reporting entities may voluntarily disclose the remaining 10 Scope 3 categories.  

  • CARB confirmed that multiple quantification methodologies remain acceptable, including spend-based, activity-based, supplier-specific, and hybrid approaches. 

Insurance Company Reporting Alignment 

Insurance companies, currently exempt from 2026 reporting to avoid duplicating California Department of Insurance (CDI) filings, would need to supplement their CDI reports starting in 2027 with any SB 253 elements CDI reporting does not address, namely Scope 3 emissions and assurance. 

Upcoming Listening Sessions 

CARB announced sector-specific virtual listening sessions running August 5 through September 9, 2026, covering data users and public-interest stakeholders, manufacturing and life sciences, agriculture and forestry, energy and transportation, retail and technology, and banking and insurance. Registration details will be released via CARB's email list. 

As CARB continues to refine SB 253 requirements, organizations should continue preparing to ensure timely and compliant reporting, particularly as expectations around the extended 2026 deadline, Scope 3 categories, and third-party assurance continue to evolve. Taking early action to assess data readiness, establish internal processes, and align with anticipated guidance will be critical.

KERAMIDA supports clients through distinct Scope 1, 2, and 3 GHG inventory development, reporting, and independent third-party assurance pathways, providing the technical expertise needed to help organizations confidently navigate and comply with SB 253 requirements.