The California Air Resources Board (CARB) has announced a delay in the initial rulemaking for the state’s landmark climate disclosure laws, California SB 253 and California SB 261 , shifting the process from October 2025 to the first quarter of 2026. The postponement reflects the significant volume of public feedback received and ongoing discussions regarding the scope of companies subject to the requirements. 

Despite this shift, reporting deadlines remain unchanged, with CARB indicating it will exercise enforcement flexibility during the initial reporting cycles. 

SB 253 applies to companies with annual revenues exceeding $1 billion doing business in California, requiring annual disclosure of Scope 1, 2, and 3 greenhouse gas emissions. SB 261, covering companies with annual revenues over $500 million, mandates public disclosure of climate-related financial risks starting January 1, 2026. Together, these regulations establish one of the most ambitious climate disclosure regimes in the United States, affecting more than 4,000 companies nationwide. 

In parallel with the timeline update, CARB has released a draft Scope 1 and 2 emissions reporting template to guide companies in preparing for compliance. The template includes fields for organizational and contact details, third-party verification, emissions inventory methodologies, quantified Scope 1 and 2 data, and optional base-year information. 

While use of the template will remain voluntary for the first reporting cycle in 2026, CARB may expand data requirements in subsequent years. Public comments on the draft are open until October 27, 2025. 

This extension provides additional time for CARB to finalize technical details and for companies to strengthen internal data management, reporting systems, and assurance processes. Businesses are advised to begin aligning their reporting structures with the template to ease the transition into mandatory disclosure.