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 in the future (not in 2026) will need to 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).