CARB SB 253 Workshop: Bold New Scope 3 Options for 2027

CARB SB 253 workshop Scope 3 reporting options

Table Of Contents

We covered the SB 253 reporting deadline extension to November 10, 2026, in our last update. That extension was about Scope 1 and Scope 2. The CARB SB 253 workshop picks up where that story left off, and turns to the harder question: how Scope 3 reporting will actually work starting in 2027.

Nothing from the July session is finalized. But the concepts CARB is testing now are the same ones that will define your Scope 3 data architecture next year, so it’s worth tracking closely rather than waiting for the final rule.

A quick recap: where the SB 253 reporting deadline stands

Before getting into Scope 3, here’s the short version of what’s already settled, in case you’re catching up:

Item
Status
Scope 1 & 2 reporting deadline
Extended to November 10, 2026
Companies in scope
U.S. entities, >$1B revenue, doing business in California
Reporting year covered
FY2025
Scope 3 reporting starts
2027 (mechanics still being defined)
First-year enforcement
Good-faith effort standard

For the full breakdown of the deadline change, see our earlier post on the SB 253 reporting deadline extension. Everything below is new ground: what CARB is proposing for the reporting cycle that follows.

What the CARB SB 253 workshop covered on July 21

The July 21 session was CARB’s fourth public workshop on the California Corporate Greenhouse Gas Reporting Program, run virtually over Zoom. The agenda had two parts: an update on Scope 1 and Scope 2 mechanics for 2027 and beyond, including data assurance, and a closer look at Scope 3 reporting options for 2027.

Both build directly on the March 23, 2026 workshop, where CARB first laid out its Scope 3 thinking. The CARB SB 253 workshop in July functions as a status check on those same concepts rather than a break from them, since the agency is still in pre-rulemaking mode and has not committed to a final approach.

Three Scope 3 options CARB is weighing

This is the part worth building your data roadmap around now. CARB has floated three regulatory frameworks for how Scope 3 reporting phases in starting 2027, and each one changes the order in which your categories or business units would need to be reporting-ready.

OptionHow it worksWho reports firstThe trade-off
1. Broad applicabilityAll reporting entities disclose all 15 Scope 3 categories in 2027, with flexibility to exclude categories shown to be de minimisEveryone, simultaneouslyHeaviest lift up front, but no ambiguity about your filing year
2. Sectoral phase-inScope 3 reporting starts in 2027 only for the highest-emitting sectors (transportation and industrial first)Companies in flagged sectorsFaster runway if you’re outside the priority sectors, less if you’re inside one
3. Category phase-inAll entities report Scope 3 in 2027, starting with the categories companies most commonly already trackEveryone, but only on their best-tracked categories firstEases the data-maturity curve, but still requires 2027 readiness

CARB has not indicated which option it favors, and public comments on the March concepts closed April 13. Until a formal proposal lands, the safest move is mapping your Scope 3 categories against all three so you’re not caught flat-footed by whichever one CARB adopts.

Assurance standards on the table

For Scope 1 and 2 limited assurance, expected to phase in from 2027, CARB is leaning toward accepting existing standards rather than writing a new one from scratch.

StandardGoverning bodyNotes
AT-C Section 210 or 205AICPACommon for U.S.-based assurance engagements
ISAE 3000 (Revised) / ISAE 3410IAASBAccepted through December 2026
ISSA 5000IAASBEffective December 2026; adopted across the EU, UK, Australia, Japan, and more
ISO 14064-3:2019ISORequires provider qualification under ISO 14065/14066

ISSA 5000 is the one to flag internally. If your company already reports under CSRD or a similar international framework, aligning to ISSA 5000 likely means reusing an existing assurance relationship instead of building a separate one for California.

Updated compliance timeline

Here’s the timeline from our last post, extended with the July 21 workshop.

Date
Milestone
2023
SB 253 and SB 261 signed into law
February 2026
CARB approves the formal SB 253/SB 261 regulation
May 20, 2026
CARB submits the regulation to the Office of Administrative Law
June 24, 2026
CARB withdraws the OAL submission, extends the Scope 1/2 deadline by three months
March 23, 2026
First workshop on Scope 3 concepts for 2027
July 21, 2026
CARB SB 253 workshop revisits Scope 3 options and assurance standards
November 10, 2026
Revised Scope 1 & 2 reporting deadline
2027
Scope 3 emissions reporting begins

What this means for your reporting roadmap

The Scope 1 and 2 extension bought you time. The Scope 3 groundwork shouldn’t wait for it.

  1. Map your Scope 3 categories against all three options. If CARB lands on sectoral phase-in and you’re in transportation or industrial, your runway is shorter than the 2027 date suggests.
  2. Decide your assurance standard early. If you already report under CSRD or TCFD, ISSA 5000 or ISAE 3000 likely lets you reuse existing relationships instead of starting fresh.
  3. Keep documenting methodology. CARB has repeated this at every workshop this year: organizational boundaries, emission factors, and accounting methods all need explanation, not just numbers.
  4. Don’t let SB 261 status affect SB 253 planning. They remain legally distinct, and the two tracks shouldn’t be managed as one project.

How Sprih helps you get ahead of Scope 3

Whichever option CARB adopts, all three require the same underlying capability: supplier-specific Scope 3 data your team can defend, not spend-based estimates. Sprih’s AI engine, SustainSense, pulls from over 400,000 sustainability reports across 150,000+ companies to build that data without sending suppliers another questionnaire. For a deeper look at the mechanics, see our guide to Scope 1, 2, and 3 reporting under SB 253 and our breakdown of the SB 253 assurance requirement.

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