SB 253 Update: CARB Delays Reporting Deadline to November 2026 and Proposes to Clarify Requirements

Companies preparing to comply with California’s Senate Bill (SB) 253 and submit their first required disclosures in August 2026 have received an update this week from the California Air Resources Board (CARB) that will delay reporting deadlines. On June 24, 2026, CARB deferred the deadline for entities to report Scope 1 and Scope 2 greenhouse gas (GHG) emissions from August 10, 2026 to November 10, 2026. The three-month deferral will provide additional time for reporting entities following the anticipated approval and formal adoption of CARB’s proposed regulation. CARB will propose limited changes to the regulation to clarify requirements. These changes will be made available for comment in a forthcoming 15-day public comment period.

SB 253 and SB 261

SB 253 and SB 261 are landmark climate disclosure and financial reporting legislation that impose reporting requirements on large U.S. public and private companies doing business in California. The legislation requires annual public disclosures of Scope 1 and Scope 2 GHG emissions beginning in 2026, and Scope 3 GHG emissions in 2027.

The legislation also would require the submission of biennial climate-related financial risk reports to CARB beginning in 2026. As of June 2026, enforcement of SB 261 remains stayed pursuant to a Ninth Circuit injunction pending an ongoing appeal being considered by the court.

Sidley previously discussed key takeaways from this legislation here and analyzed updates to CARB’s proposed regulation here.

CARB Regulation, Proposed Revision, and Delay of Reporting Deadline

On February 26, 2026, CARB approved an Initial Regulation under SB 253 and submitted the regulation to the Office of Administrative Law (OAL) for approval. The June 24, 2026 update follows CARB’s withdrawal of the Initial Regulation to revise and clarify requirements.

According to CARB, a revised regulation will be published for a 15-day public comment period before being resubmitted to OAL. CARB has not yet made the revised regulatory text available and has not published notice opening the comment period. CARB has stated that the three-month extension of the Scope 1 and Scope 2 reporting deadline is intended to ensure reporting entities have additional clarity following the approval of the final regulation before reporting is due.

Business Takeaways

Companies subject to SB 253’s Scope 1 and Scope 2 GHG disclosure requirements should be aware that the reporting deadline has been delayed to November 2026, and should monitor CARB’s rulemaking developments for announcement of CARB’s revised regulation and publication of notice of the opening of the 15-day comment period. Companies should continue to assess how CARB’s proposed revisions and clarifications will impact their reporting. Upon opening of the public comment period, impacted entities may wish to submit comment on the clarifications.

Summer associate Lexi Detrick also contributed to this blog post.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.