The California Air Resources Board (CARB), the regulator charged with developing and enforcing the state’s new corporate climate reporting regulations, announced the release of new guidance for companies set to begin reporting GHG emissions this year under the state’s new climate reporting regulations, with initial reports due on November 10^th.

The new guidance confirms a series of measures by the regulator to “exercise enforcement discretion” to ease the transition into the new reporting requirements for companies, including allowing the use of emissions data already collected for the prior fiscal year, not requiring Scope 1 and 2 data from companies that had not yet collected the data in the past, and accepting emissions data even without limited assurance, for the 2026 reporting cycle.

California’s new emissions reporting regulation, SB 253, will require companies with revenues greater than $1 billion that do business in California to report annually on their direct Scope 1 and 2 emissions in the first year of disclosure, and to add Scope 3 value chain emissions disclosure beginning in subsequent years.

In its initial enforcement notice in 2024, however, CARB announced plans to exercise discretion in its enforcement of the regulation at the beginning of reporting, noting that it “recognizes that companies may need some lead time to implement new data collection processes” in order to fully report on their Scope 1 and 2 emissions.

The new guidance confirms key measures provided by the regulator during the transition period, including allowing companies to submit Scope 1 and Scope 2 emissions for their prior fiscal year based on information they already have or were collecting when the 2024 enforcement notice was released, and allowing companies that were not collecting or planning to collect data at the time of the enforcement notice to not submit Scope 1 and 2 reporting data for the first reporting cycle. Companies that will not submit data during the first cycle are requested to submit a statement of non-reporting on company letterhead.

For the first year of reporting, CARB said that it will allow for a variety of formats for the submitted data, including existing annual reports including Scope 1 and 2 emissions, existing Scope 1 and 2 data reported to other programs or voluntary initiatives, or CARB’s Draft Scope 1 and 2 Template. CARB also indicated that it will not require the use of a specific emission factor dataset for 2026 GHG emissions reporting.

While the new regulation requires limited assurance for reporting, CARB’s guidance said that the regulator will accept submissions whether or not assurance has been obtained for the 2026 cycle.

Beyond the first cycle, CARB said that it is currently undertaking a rulemaking cycle in which it is developing the reporting requirements for 2027 and subsequent years, covering areas including GHG accounting methodologies, deadlines, assurance requirements, and reporting formats.

Alongside the new guidance, CARB also announced launched a new voluntary intake platform to assist companies with submitting their initial reports under the regulation.

Alongside the new guidance, CARB also announced launched a new voluntary intake platform to assist companies with submitting their initial reports under the regulation.

Click here to access CARB’s new guidance and intake platform.