The California Air Resources Board (CARB) released its 2026 SB 253 Reporting Guidance and a voluntary Greenhouse Gas Report Intake Platform in September 2026, giving covered companies the tools to file their first Scope 1 and 2 emissions reports under the Climate Corporate Data Accountability Act. US companies with more than USD 1 billion in annual revenue doing business in California, including Apple, Chevron, Alphabet and Walmart, must prepare and submit their first 2026 Scope 1 and 2 greenhouse gas emissions reports using the new guidance and intake platform by November 10, 2026, or face CARB civil penalties of up to USD 500,000 per year under SB 253.
The release keeps the November 10, 2026 reporting deadline live. CARB had moved the first Scope 1 and 2 deadline from August 10, 2026 to November 10, 2026 when it withdrew its Initial Regulation on June 24, 2026 for clarifying changes, and the guidance and platform are the practical means of meeting it. SB 253 itself is not enjoined: only SB 261 enforcement is paused under the Ninth Circuit injunction in Chamber of Commerce v. Sanchez.
What did CARB release in its 2026 SB 253 guidance?
The 2026 Reporting Guidance Document sets out how covered entities prepare and submit their Scope 1 and 2 emissions reports under SB 253 and the Initial Regulation. CARB paired it with a voluntary 2026 Report Intake Platform hosted on its ArcGIS portal, where companies submit fee contact information and emissions data, and a video tutorial walking reporters through the process. The program page also added an SB 261 docket instructions link and retained the November 10, 2026 deadline language.
The guidance and platform are operational resources, not new legal obligations: the duty to report comes from SB 253 itself and the Initial Regulation CARB is finalizing. They matter because they tell covered entities exactly what a compliant 2026 submission looks like for the first reporting cycle, removing the ambiguity that surrounded the original August deadline.
Who must report Scope 1 and 2 emissions, and by when?
SB 253 (Chapter 382, Statutes of 2023) reaches US entities with more than USD 1 billion in total annual revenue that do business in California, regardless of where they are incorporated. For the first cycle, these companies must report Scope 1 and 2 greenhouse gas emissions by November 10, 2026. Scope 3 reporting follows from 2027, limited assurance from 2027, and reasonable assurance from 2030.
| Milestone | Date |
|---|---|
| Initial Regulation approved by CARB | February 26, 2026 |
| Initial Regulation withdrawn for clarifying changes | June 24, 2026 |
| First Scope 1 and 2 reporting deadline | November 10, 2026 |
| Scope 3 reporting begins | 2027 |
| Limited assurance | 2027 |
| Reasonable assurance | 2030 |
The deadline moved from August 10, 2026 to November 10, 2026 when CARB withdrew the Initial Regulation. A revised rule is going through a 15-day comment period before resubmission to the Office of Administrative Law (OAL), which reviews regulations for necessity, authority and clarity before they take effect in the California Code of Regulations. OAL approval is what makes the fee schedule and reporting requirements legally binding, but the November 10, 2026 deadline stands regardless.
Is the November 10, 2026 deadline still live despite the litigation?
Yes. SB 253 is not enjoined. The Ninth Circuit injunction of November 18, 2025 in Chamber of Commerce v. Sanchez pauses enforcement of SB 261, the separate Climate-Related Financial Risk Act covering entities above USD 500 million in revenue, not SB 253. Oral argument was heard on January 9, 2026 and a ruling is expected later in 2026. CARB's December 1, 2025 enforcement advisory confirmed it will not enforce the SB 261 January 1, 2026 deadline while the injunction holds, and will set an alternate date after the appeal.
For SB 253 reporters, the November 10, 2026 Scope 1 and 2 deadline is firm. CARB is actively building reporting infrastructure for it, which the September 2026 guidance and intake platform release confirms.
What happens if a covered entity misses the deadline?
SB 253, as amended by SB 219 (Chapter 766, Statutes of 2024), exposes non-compliant covered entities to CARB civil penalties of up to USD 500,000 per year. CARB enforces the regime. The penalty accrues per year of non-compliance, not as a one-off fine, so the exposure accumulates for reporters that fail to submit.
Obsidian's continuous, per-jurisdiction monitoring surfaces this kind of guidance release the moment CARB publishes it, so compliance teams are not working from a stale snapshot.
What to do next
- Confirm whether your entity meets the USD 1 billion revenue and doing-business-in-California thresholds for SB 253.
- Download the 2026 Reporting Guidance and register on the voluntary Report Intake Platform ahead of the November 10, 2026 deadline.
- Map your Scope 1 and 2 emissions data to the guidance's reporting format, and line up limited assurance for 2027.
- Brief your sustainability, legal and finance teams on the separate, paused SB 261 track to avoid conflating the two regimes.
