CARB Proposes Revised California GHG Reporting Deadline

California GHG reporting matters beyond California. Manufacturers, importers, retailers and corporate groups may need data from facilities, energy suppliers and business units across the United States and overseas. The 15-day comment period closes on 11 August 2026.

CARB Reopens The Climate Disclosure Rulemaking

The Board approved its initial regulation on 26 February and submitted it to the Office of Administrative Law on 20 May. CARB subsequently withdrew the package for limited changes. The California GHG reporting modification is therefore a proposal within an active rulemaking, not a final approved extension.

The initial regulation implements parts of California's Climate Corporate Data Accountability Act and Climate-Related Financial Risk Act. SB 253 covers US-based entities with more than $1 billion in annual revenue that do business in California. It requires annual Scope 1 and Scope 2 reporting, followed by Scope 3 reporting under the statutory timetable. The package also establishes definitions and an initial fee programme.

Scope 1 And Scope 2 Data Still Need Attention

Scope 1 covers direct emissions from sources an organisation owns or controls. Scope 2 covers indirect emissions from purchased electricity, steam, heat and cooling. California GHG reporting teams should reconcile organisational boundaries, emissions factors, utility evidence and assurance plans rather than treating the proposed delay as a pause.

Supply-chain teams may also face requests for supporting activity data. Although the modified first-year deadline concerns Scope 1 and Scope 2, procurement records and facility data can affect group calculations and later Scope 3 work.

What Companies Should Do Before 11 August

Legal and sustainability teams should confirm whether revenue and California business-presence tests apply, review the modified definitions, and document any assumptions. Organisations affected by unclear wording can comment only on the listed modifications by 11 August. Until OAL approval and formal adoption, compliance plans should track both the current rule and the proposed 10 November date.

Summary

CARB has proposed moving California's first Scope 1 and Scope 2 reporting deadline to 10 November 2026. Large businesses should confirm scope, reconcile emissions evidence and monitor approval. The extra three months can strengthen assurance and governance, but the modified regulation remains under review and comments close on 11 August.