Client Alert: SB 253 Key Updates from CARB Nov 18 Workshop

/

IMPORTANT: While CA SB 253 remains in effect, on November 18, 2025, a U.S. appeals court temporarily froze (halted the implementation of) California SB 261. Read more.

Proposed Key Updates for SB 253 from Nov. 18 CARB Workshop

CARB has released proposed updates on first-year reporting requirements under SB 253 for Scope 1 and Scope 2 greenhouse gas (GHG) emissions during the November 18 workshop. Below is a summary of the key points: 

First-Year Reporting Deadline 

CARB is proposing an updated reporting deadline of August 10, 2026, for SB 253 Scope 1 and Scope 2 GHG emissions. 

Proposed Definitions and Exemptions 

  • CARB proposed defining “doing business in California” using Revenue and Tax Code § 23101 and omitting Section 23101(b)(3-4) relating to property holdings and payroll. 

  • CARB proposed defining a subsidiary as a business entity controlled or owned through direct corporate association, consistent with the definition provided in Title 17, California Code of Regulations, § 95833. 

  • CARB proposes exemptions for non-profits/charitable organizations, entities whose only California presence is teleworking employees. 

Determining Your Applicable Reporting Year 

The reporting year for Scope 1 and Scope 2 GHG emissions will depend on an entity's fiscal year (FY) end: 

  • If the FY ends between January 1 and February 1, 2026: The entity will report GHG emissions from the FY ending in 2026. 

  • If the FY ends between February 2 and December 31, 2026: The entity will report GHG emissions from the FY ending in 2025. 

Reporting Format Options 

  • Entities may use CARB's draft Scope 1 and Scope 2 reporting template, although its use is optional, not mandatory. 

  • Entities can also submit existing GHG reports, provided these reports already disclose Scope 1 and Scope 2 emissions. 

Limited Assurance Requirements 

Third-party limited assurance will not be required for 2026 submissions; however, CARB will require third-party limited insurance beginning in 2027 and subsequent years. 

Although third-party limited assurance is not required for 2026 submissions, it will become mandatory beginning in 2027. Given that all CARB-reported data will be publicly accessible, KERAMIDA strongly recommends that companies pursue assurance for their 2026 reporting to ensure accuracy and readiness for future compliance requirements.  

Special Provision for Entities Not Collecting Data 

If an entity was not collecting GHG emissions when CARB issued its December 2024 Enforcement Notice, it may submit a statement on company letterhead to explain the non-reporting and clarify that the company was not collecting, or planning to collect, GHG data at the time the notice was issued. 

For questions regarding SB 253 contact:

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

Email Xuqing at xxiong@keramida.com