The California Air Resources Board (CARB) held a virtual public workshop yesterday to support the development of the California Corporate Greenhouse Gas Reporting Program authorized by SB 253 (Wiener, Stats. 2023; codified in Health & Safety Code (HSC) § 38532), as amended by SB 219 (Wiener, Stats. 2024, Chapter 766; codified in HSC §§ 38532 and 38533). 

The workshop included an update from CARB staff on additional information for the August 10, 2026, Scope 1 and Scope 2 emissions reporting deadline. The workshop also covered the next stage in regulatory development and provided an overview of the development of the greenhouse gas reporting requirements for 2027-2030 under HSC § 38532.

Discussion included preliminary staff options for Scope 3 emissions reporting requirements for 2027-2030, solicitation of alternative approaches, and an overview of staff’s approach to the economic analysis.  

Access the presentation slides HERE, which include specific items CARB is requesting feedback on. A sampling of these items are listed below. To view all of CARB's questions for informing your company's comments, be sure to download the slides.

Please send feedback to be submitted under CRA to sarah@calretailers.com by Wednesday, April 8.

As a reminder, the law currently under a stay is SB 261 (Stern-2023), the Climate-Related Financial Risk Reporting Act; SB 253 remains in effect. Enforcement is enjoined by the Ninth Circuit, so CARB is not enforcing SB 261 and reporting under it is effectively voluntary pending the appeal. CARB’s implementing regulation, including the August 10, 2026 Scope 1 and 2 reporting deadline, is moving forward and is not covered by the injunction.

Sample of Questions CARB is Seeking Feedback On For SB 253 Rulemaking:

• If companies report under another jurisdiction’s program, what elements of that framework should CARB take into account?
  
• Are there topics from the initial regulation adopted at the February 2026 Board hearing that need to be revisited, including reporting deadline post 2026, applicability definitions, and/or exemptions?
  
• Are there other approaches to organizational boundary setting that CARB should consider?
  
• How should entities explain their choice of organizational boundary? Organizational boundaries establish direct emissions a company is responsible for. Important to clearly define these to avoid double counting and other issues.
  
• Are the costs presented in this workshop in the ballpark of your company’s estimates for compiling, reporting and assuring GHG emissions?
  
• Will most of the costs associated with reporting be incurred in state or through offices in other jurisdictions (e.g.: headquarters in other states, countries)?
  
• Provide alternatives to the draft regulatory proposal discussed today.
  
• Are the sectors listed in Option 2 (see slide) the appropriate starting point for a phased approach to scope 3 reporting? What factors should CARB consider in confirming or adjusting this prioritization?

For questions on these rulemakings, please contact sarah@calretailers.com.