California has confirmed a series of first-year relief measures for companies preparing to report greenhouse gas emissions under the state’s Climate Corporate Data Accountability Act, SB 253.
The California Air Resources Board (CARB) has introduced additional flexibility for the first reporting cycle as companies transition into the new requirements. Under CARB’s Initial Regulation, the first Scope 1 and Scope 2 emissions reports are scheduled to be submitted on or before November 10, 2026.
The relief covers areas including existing emissions data, reporting formats, emission factors, and limited assurance. However, it does not change the broader direction of California’s climate reporting requirements, which are expected to expand to Scope 3 value-chain emissions in subsequent reporting cycles.
SB 253 generally applies to qualifying U.S. business entities doing business in California with annual revenues exceeding $1 billion.
What Has Changed for the 2026 Reporting Cycle?
Companies Can Use Emissions Data They Already Have
For the first reporting cycle, companies may submit Scope 1 and Scope 2 emissions information that they already possessed or were already collecting when CARB issued its December 5, 2024 Enforcement Notice.
This means companies do not necessarily need to rebuild their emissions reporting process or produce an entirely new report solely for the 2026 submission.
Existing annual reports containing Scope 1 and Scope 2 information, or emissions information already submitted through another regulatory or voluntary reporting program, may be used.
Some Companies Will Not Be Expected to Submit Emissions Data in 2026
CARB has also provided relief for companies that were not collecting or planning to collect Scope 1 and Scope 2 emissions data when the December 2024 Enforcement Notice was issued.
For the first reporting cycle, these companies are not expected to submit Scope 1 and Scope 2 emissions data.
CARB recommends that these entities submit a statement of non-reporting on company letterhead, indicating that they were not collecting and were not planning to collect the relevant Scope 1 and Scope 2 emissions data when the Enforcement Notice was issued on December 5, 2024. CARB recommends this approach for the 2026 reporting cycle.
CARB’s Reporting Template Is Optional
Companies will have flexibility over how they submit their first Scope 1 and Scope 2 report.
CARB will accept existing reports or emissions information already prepared through other reporting programs. Companies may also choose to use CARB’s Scope 1 and Scope 2 reporting template.
The CARB template is therefore an option rather than a mandatory reporting format for 2026.
CARB’s 2026 Intake Platform Is Also Voluntary
CARB has introduced a voluntary 2026 report intake platform to support first-year reporting.
Reporting entities may use the platform to provide contact and billing information and, if they choose, submit their Scope 1 and Scope 2 emissions report directly through it.
Use of the platform is not mandatory. Entities may also submit their reporting information separately through the channels provided by CARB.
For entities relying on CARB’s first-year enforcement approach because they were not collecting or planning to collect Scope 1 and Scope 2 data as of December 5, 2024, the platform can also be used to submit a statement of non-reporting.
No Specific Scope 2 Emission Factor Dataset Is Required
For 2026 reporting, CARB’s Initial Regulation would not require reporting entities to use a specific emission factor dataset for Scope 2 emissions calculations.
CARB notes that companies may use the latest official U.S. EPA eGRID release, eGRID 2023, the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative, or other credible emission factor sources.
Where alternative emission factors are used, CARB encourages companies to identify the factors and their sources.
CARB Encourages Additional Reporting Detail Where Available
For 2026, reporting entities submitting emissions reports would provide their annual Scope 1 and Scope 2 emissions, subject to CARB’s first-year enforcement discretion.
CARB also encourages companies to provide additional context where available, including information about:
- Calculation methodologies
- Data sources
- Global warming potential values
- Emission factors and their sources
- Organizational boundaries
- Emissions by category and greenhouse gas
- Assumptions used in preparing the reported figures
Providing this information can give important context to reported emissions and strengthen the traceability of the underlying calculation process.
Reports Will Be Accepted Without Limited Assurance
SB 253 introduces third-party assurance requirements for corporate emissions reporting.
However, CARB has confirmed that it will exercise enforcement discretion for the first 2026 report and accept Scope 1 and Scope 2 information whether or not limited assurance has been obtained.
This provides additional transition time, but companies should not interpret it as removing the need to prepare their emissions data, methodologies, evidence, and controls for future assurance requirements.
What About Scope 3?
CARB’s September 2026 guidance applies specifically to the first 2026 Scope 1 and Scope 2 reporting cycle. It does not establish the detailed reporting requirements for 2027 and subsequent years.
Scope 3 nevertheless remains part of the broader SB 253 reporting framework. Under SB 253, covered entities are also required to report indirect upstream and downstream Scope 3 emissions, starting for reporting year 2027.
CARB is currently undertaking a second rulemaking process to develop requirements for 2027 and subsequent reporting years, including GHG accounting methodologies, deadlines, assurance requirements, and reporting formats.
For many organizations, Scope 3 will be substantially more challenging than Scope 1 and Scope 2 because relevant information can sit across:
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Suppliers and purchased goods
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Transportation and logistics
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Business travel
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Distribution
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Product use
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Investments
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Waste and end-of-life activities
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Other upstream and downstream business relationships
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Companies should therefore avoid treating the 2026 relief as a reason to postpone Scope 3 readiness.
The first reporting year provides an opportunity to establish the data structures, ownership, methodologies, evidence, and review processes that will be needed as California’s reporting requirements develop.
What Should Companies Do Now?
Companies potentially covered by SB 253 should use the additional flexibility to strengthen the reporting process rather than simply focus on the November submission.
Key priorities include:
- Confirm the organization’s reporting obligations under SB 253
- Identify the Scope 1 and Scope 2 information available for the 2026 submission
- Document reporting boundaries and calculation methodologies
- Maintain the emission factors, assumptions, estimates, and source information behind reported figures
- Preserve supporting documentation and evidence
- Define internal data ownership, review, and approval responsibilities
- Assess readiness for future assurance requirements
- Map relevant upstream and downstream value-chain activities
- Identify the data sources required for Scope 3 calculations
- Establish processes for managing supplier data, estimates, proxies, and supporting evidence
Companies should also continue monitoring CARB’s regulatory development as requirements for future reporting cycles are finalized.
How EcoActive Supports Scope 1, Scope 2 and Scope 3 Reporting
California’s first-year enforcement flexibility may reduce some immediate reporting pressure, but organizations still need to manage the data, methodologies, emission factors, assumptions, supporting evidence, reviews, and disclosures behind their reported emissions.
EcoActive supports the collection and calculation of Scope 1, Scope 2, and relevant Scope 3 greenhouse gas emissions within a connected disclosure management environment.
Integrated GHG Emissions Management
EcoActive’s GHG Calculator helps organizations manage emissions calculations across Scope 1, Scope 2, and Scope 3, connecting activity data with relevant emission factors and calculation methodologies.
Instead of managing emissions calculations separately from the reporting process, organizations can maintain the connection between underlying data, calculations, supporting information, and resulting disclosures.
Scope 3 and Value Chain Management
Scope 3 reporting introduces an additional challenge because much of the required information originates outside a company’s direct operations.
EcoActive’s Value Chain Management capability helps organizations organize sustainability information across upstream and downstream activities and connect relevant value-chain data with Scope 3 emissions reporting.
This can include information relating to suppliers, purchased goods and services, transportation, logistics, distribution, customers, product use, and end-of-life activities.
Relevant value-chain information can be connected directly with EcoActive’s GHG Calculator across applicable Scope 3 categories.
Traceability From Data to Disclosure
EcoActive helps maintain the relationship between:
Value Chain → Activity Data → Emissions Calculation → Evidence → Review → Disclosure
Reporting teams can retain source information, methodologies, assumptions, emission factors, supporting evidence, reviews, and changes alongside the information being reported.
This becomes increasingly important as emissions reporting moves toward greater regulatory scrutiny and assurance.
Controlled Review and Assurance Readiness
EcoActive also supports structured review and approval workflows around reported information.
Teams can maintain review history, supporting documentation, comments, approvals, and changes behind emissions figures and disclosures instead of managing these processes across disconnected spreadsheets, emails, and documents.
While CARB is allowing 2026 submissions without limited assurance under its first-year enforcement approach, establishing controlled and traceable reporting processes now can help organizations prepare for future assurance requirements.
Explore EcoActive ESG Reporting | Explore EcoActive Value Chain Management
Looking Ahead
CARB’s latest guidance reduces some of the immediate burden associated with California’s first year of mandatory emissions reporting.
But the relief is best viewed as a transition measure, not a reduction in the long-term reporting requirements.
The immediate priority is Scope 1 and Scope 2. The next challenge is building the value-chain data infrastructure required for Scope 3.
Companies that use the 2026 reporting cycle to establish consistent emissions calculations, documented methodologies, supporting evidence, clear ownership, controlled reviews, and structured value-chain data will be better positioned as California’s climate reporting framework develops.
Prepare for California Climate Reporting with EcoActive
Build a more controlled, traceable process for Scope 1, Scope 2, and Scope 3 emissions reporting—from data collection and calculation to review, evidence, and disclosure. See how EcoActive can support your California climate reporting readiness.
