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2025 has been an unprecedented time of change, including uncertainty around climate related policy. Despite some delay and ongoing litigation, California’s climate disclosure laws: SB 253, SB 261, and SB 219, affectionately called, “the 200’s” are moving forward.

In August the California Resources Board (CARB) released regulation frameworks, definitions, and additional guidance. Below we outline what you need to know about the most recent updates.

What Are California’s Climate Disclosure Laws?

In 2023 California passed SB 253: The Climate Corporate Data Accountability Act, and SB 261: The Climate-Related Financial Risk Act. Here’s a high-level overview of their requirements:

SB 253

Who needs to report?

• Corporations that do business in California and made over $1 billion in revenue in the previous fiscal year.

What is reported?

• The company’s scope 1, 2, and 3 Greenhouse Gas Emissions.

When is the reporting deadline?

• 2026 (scope 1 and 2 emissions) and 2027 (scope 3 emissions); reports annually thereafter.

SB 261

Who needs to report?

• Corporations that do business in California and made over $500 million in revenue in the previous fiscal year.

What is reported?

• The company’s climate-related financial risk and mitigation strategy.

When is the reporting deadline?

• January 1, 2026; reports biennially thereafter.

Meeting these reporting requirements involves in-depth carbon accounting and accurate data collection. Scope emissions must be measured precisely, and reports must be assurance-ready.

SB 219 Amendments

In the two years since the initial passing of the bills, many stakeholders brought forward concerns over how to comply. That is where SB 219 comes into play. Passed into law in 2024, SB 219 is the companion bill that updates the following details:

• Granted California Air Resources Board (CARB) discretion to set a distinct Scope 3 emissions reporting schedule. Previously, they were required within 180 days of Scope 1 and Scope 2 emissions disclosure.
• Allows CARB to directly receive GHG emissions reports rather than through an “emissions reporting organization”. They still have the option to delegate this duty to a reporting organization.
• Allows subsidiaries to consolidate SB 253 reports under parent companies, which was previously only specified for SB 261 reports.
• Gave CARB until July 1, 2025 to specify regulations for reporting GHG emissions. In the initial bill text, they were supposed to do so by January 1, 2025.

Remember that these changes did not impact the reporting schedule for SB 253 and SB 261 – they simply updated some of the details.

Key Takeaways from CARB’s Updated Guidance

In their most recent public workshop held on August 21, 2025, CARB provided additional guidance on regulation development and implementation, reporting, and timeline requirements. Here is the complete Virtual Public Workshop recording and presentation. CARB also released this Climate Related Financial Risk Disclosures: Draft Checklist, which provides guidelines for SB 261 reporting.

Below is a selection of additional guidance from the 8/21/25 workshop:

SB 253

Scope 1 and 2 reporting deadline is proposed for June 30, 2026 (2025 data).

• This is not yet a final deadline; CARB staff is taking public feedback.
• Scope 1 and 2 reports will need to be verified and (initially) meet “limited assurance”. This means data collection, hygiene, and transparency are paramount. Green Econome’s data consulting services can help you get your data assurance ready.

Allows for the use of existing reporting standards, such as the GHG protocol, ISO 14064, TCFD, CSRD, etc.

SB 261

CARB will open a public docket for SB 261 reporting entities to post a link to their initial financial risk reports (due January 1, 2026).

The disclosure requirement is every two (2) years.

CARB will accept “good faith effort” reports for SB 261, meaning in 2026 they will accept climate-related risk reports that were prepared to the best extent possible by the entity.

Reporting entities may use any of the following frameworks for Climate-Related Financial Risk Reports:

• The Final Report of Recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) (June 2017) published by the TCFD (or any successor)
• The International Financial Reporting Standards Sustainability Disclosure Standards, as issued by the International Sustainability Standards Board (IFRS S2)
• A report developed in accordance with any regulated exchange, national government, or other governmental entity, including a law or regulation issued by the United States government (see HSC § 38533(b)(3)(A) for details).

How Companies Can Prepare for SB 253

• Build a reliable data collection and management system for tracking Scope 1, 2, and 3 emissions. The sooner you have this in place, the better positioned you are for near-term reporting and long-term corporate requirements. Green Econome blends online data platforms and human expertise to create a robust system that responds to your needs.
• Secure your verification and assurance providers early. If you haven’t already, now is the time to get your team in place. As these climate laws take effect, in California and globally, the market will be under pressure.
• Step 3: Scope 3. There is a reason SB 253 and other reporting requirements are delaying Scope 3 emissions. It’s complex, hard to measure, and verify. You need to start tackling your scope 3 with 1 and 2, because it may take you that extra time to get it assurance ready.

Using Climate Disclosure to Gain a Competitive Advantage

Many stakeholders in the industry see these reporting laws as headaches and hurdles for their business. But could they also be an advantage?

Reporting GHG emissions and climate-related risks transparently could attract investors looking for long-term value. From a business perspective, these reports can be eye-opening and with proper analysis could be a value-add that improves the company’s resilience over time.

Let’s also not forget the potential non-compliance penalties upwards of $500,000 (SB 253) and $50,000 (SB 261) each reporting year.

How Can Green Econome Help?

Green Econome provides multiple related services for SB 253 reporting. We can perform ENERGY STAR® benchmarking, data collection, data verification, carbon accounting of your GHG emissions, and provide ongoing support for your long-term compliance. We have been entrusted by large, publicly traded companies and are ready to help you meet these stringent requirements. Reporting can take time, and the initial deadlines are fast approaching. Contact us to see how we can assist your team today.