The California Air Resources Board (CARB) has released a list of more than 4,000 companies required to comply with the state’s new climate reporting laws. These regulations mandate disclosures on climate-related risks and opportunities, and for some companies, on value chain greenhouse gas (GHG) emissions. 

The new reporting laws, SB 253 and SB 261, were approved by Governor Newsom in 2023 and signed into law in October 2024. SB 253 requires companies with revenues greater than $1 billion that operate in California to report annually on their direct Scope 1 and 2 emissions, as well as Scope 3 value chain emissions, including those associated with supply chains, business travel, employee commuting, procurement, waste, and water usage. SB 261 applies to U.S. companies with revenues over $500 million doing business in California, requiring a report on climate-related financial risk and measures to reduce or adapt to that risk. 

Scope 1 and 2 emissions reporting under the new law is scheduled to begin in 2026, covering the previous fiscal year. Scope 3 emissions reporting will begin in 2027, and the first climate-related risk reports are to be published by January 1, 2026. 

The CARB list includes 4,160 U.S. companies, encompassing the majority of S&P 500 constituents. Around 60% (2,503) of the listed companies are based outside California. Most companies (2,596) will be required to comply with both SB 253 and SB 261, while 1,564 will be subject only to SB 261. 

CARB noted that the list is preliminary and may not include all companies covered by the new climate-related reporting laws. It is based on data from March 2022. Companies are still responsible for reporting under the regulations even if they are not on the list. The list may also include companies exempt from reporting, such as subsidiaries if a parent company files a consolidated report on their behalf.