What matters to me today are more CARB climate disclosure “maybe” ‘s.
Tic toc . . . statutory deadlines for the public are running out even as the legislative mandates for the California Air Resources Board (CARB) itself have been missed with impunity. Nonetheless, those subject to unprecedented climate disclosure mandates in the United States have just 70 days for compliance. Statutory deadlines, it appears, are hard and fast for the regulated community but for the regulatory agency, not so much.
CARB’s latest release is a suggested, though not mandatory, draft template for reporting Scope 1 and Scope 2 greenhouse gas emissions under California’s SB 253. The statutory deadline for CARB to promulgate implementing regulations for SB 253 was originally January 1, 2025. Having missed that deadline, the Legislature extended it to July 1, 2025, which was similarly missed. The 17-day public comment period on the draft template guidance closes on October 27, 2025. At this point, the compliance deadline for SB 253 remains “tbd” in 2026.
Reporting mandates under SB 253’s companion law, SB 261 relating to climate “risks,” is fixed in statute – January 1, 2026 (thus the 70-day clock referenced above). Those mandates apply to enterprises with a mere $500 million in annual revenue; SB 253 snags those with $1 billion or more annually. Under the Greenhouse Gas Protocol, the North Star for SB 253, three types of emissions apply: Scope 1, Scope 2, and Scope 3. Under political pressure pending SB 253’s adoption, the author graciously punted Scope 3 compliance one year to 2027. Implementing regs, again, “pending.”
That’s what matters to me today in 250 words or less. What matters to you? I’d really like to know.