On November 10, 2026, CARB's working target falls for the first-year Scope 1 and Scope 2 report under the Initial Regulation (17 CCR sections 96070-96077) implementing SB 253 (Health and Safety Code section 38532), as amended by SB 219 (2024). U.S. entities above USD 1 billion in revenue that do business in California must submit that report to CARB by November 10, 2026, or SB 253 authorizes penalties of up to USD 500,000 per reporting year.
The CARB Board approved the package on February 26, 2026 and sent it to the Office of Administrative Law. A bulletin of June 24, 2026 withdrew it for clarifying revisions and moved August 10, 2026 to November 10, 2026. Publication and entry into force are unset, so the date stays a working target pending approval. Limited assurance is not required for the 2026 report, Scope 3 is not due in 2026, and discretion does not waive the filing.
- Deadline : November 10, 2026 (working target, deferred from August 10, 2026, pending Office of Administrative Law approval).
- Who : U.S. entities above USD 1 billion that do business in California (organized or commercially domiciled there, or California sales above the Franchise Tax Board threshold).
- What : Scope 1 and Scope 2 for the applicable preceding fiscal year (fiscal year 2025 for most). No limited assurance. No Scope 3 in 2026.
- Otherwise : Up to USD 500,000 per reporting year. Discretion does not waive the filing.
- Official source : CARB bulletin of June 24, 2026.
What applies on November 10, 2026
Due on November 10, 2026 is the Scope 1 and Scope 2 report for the applicable preceding fiscal year, fiscal year 2025 for most entities. Scope 3 starts in 2027 (data year 2026), with limited assurance from 2027 and reasonable assurance from 2030 in a separate rulemaking. The September 10, 2026 fee is separate: program costs divided by the number of reporting entities, for SB 253 and SB 261 entities.
| Step | Date | Dossier status |
|---|---|---|
| Board vote | February 26, 2026 | Approved, submitted to the Office of Administrative Law |
| Withdrawal | June 24, 2026 | Clarifying revisions; filing moved from August 10, 2026 |
| Program fee | September 10, 2026 | First invoices, separate from the greenhouse gas filing |
| First filing | November 10, 2026 | Scope 1 and Scope 2, working target, pending approval |
| Scope 3 | 2027 | First Scope 3 year, data year 2026 |
Who is covered
U.S. entities above USD 1 billion that do business in California are covered: organized or commercially domiciled in California, or California sales above the Franchise Tax Board threshold. Insurers, nonprofits and government entities are exempt. SB 253 is not enjoined. SB 261 (above USD 500 million) stays unenforced under the Ninth Circuit injunction of November 18, 2025. This is a CARB rule, not an SEC rule.
What to do before November 10, 2026
- Confirm revenue above USD 1 billion and the doing-business test (California organization, commercial domicile, or sales above the Franchise Tax Board threshold).
- Assemble Scope 1 and Scope 2 for the applicable preceding fiscal year (fiscal year 2025 for most entities).
- Submit that report to CARB by November 10, 2026, pending Office of Administrative Law approval.
- Leave limited assurance and Scope 3 out of the 2026 filing.
- Pay the September 10, 2026 fee as its own obligation.
- Do not file an SB 261 report on this date while the November 18, 2025 injunction stands.
What happens otherwise
CARB enforces SB 253 penalties of up to USD 500,000 per reporting year. Discretion drops limited assurance for the 2026 report and does not waive the filing. SB 261's penalty of up to USD 50,000 per year is not enforced under the November 18, 2025 injunction. The Office of Administrative Law has not set an effective date. Continuous, per-jurisdiction monitoring surfaces a CARB date change the day the bulletin is published.
