Timeline for California Climate Disclosures: SB 253 & SB 261

SB 253 and SB 261 compliance timeline

Table Of Contents

Businesses must understand the SB 253 and SB 261 timeline as California’s climate compliance clock ticks, with mandatory emissions and risk reporting starting in 2026.

This timeline breaks down the major deadlines, what’s required, and how to prepare.

At-a-Glance: Key Dates

DateRequirement
Jan 1, 2025SB 253 regulations must be adopted
Jan 1, 2026First SB 253 Scope 1 & 2 disclosures due
Jan 1, 2026First SB 261 risk report due
2027 (mid-year)SB 253 Scope 3 disclosures begin (180 days after Scope 1 & 2)
2030Reasonable assurance required for Scope 1, 2, and Scope 3 emissions

Visual Timeline

SB 253 and SB 261 timeline reporting requirements demand companies with $1B+ in annual revenue doing business in California disclose emissions annually.

Visual timeline of SB 253 and SB 261 reporting deadlines between 2025–2030

SB 253: Emissions Disclosure Timeline

Applies to: Companies with $1B+ in annual revenue doing business in California
What’s required: Annual public disclosure of Scope 1, 2, and 3 GHG emissions
Standard: Greenhouse Gas Protocol
Assurance: Third-party limited (then reasonable) assurance required

Timeline:

YearDisclosureNotes
2025CARB adopts implementing rulesDeadline: Jan 1, 2025
2026First Scope 1 & 2 reportingMust follow GHG Protocol
2027First Scope 3 reportingDue within 180 days after Scope 1 & 2
2030Reasonable assurance beginsFor Scope 1, 2, and 3 (if required)

SB 261: Climate Risk Disclosure Timeline

Applies to: Companies with $500M+ in revenue doing business in California
What’s required: Biennial climate-related financial risk reports
Standard: TCFD (or equivalent, e.g. ISSB)
Disclosure: Public on company’s website

Timeline:

YearDisclosureNotes
2026First report dueDeadline: Jan 1, 2026
2028Second report dueContinues every two years

What To Do Now

Here’s your checklist if you’re likely subject to SB 253 or SB 261:

  • Confirm revenue thresholds ($500M or $1B+)
  • Assess current GHG data collection capabilities
  • Identify emission data gaps (especially Scope 3)
  • Assign internal owners for climate risk reporting
  • Choose standards (GHG Protocol, TCFD, ISSB)
  • Set up a timeline tracker aligned to these dates
  • Prepare for assurance provider engagement (SB 253)

Set up an internal SB 253 and SB 261 timeline tracker to stay ahead of deadlines and prepare for assurance provider engagement. Contact us for a walkthrough or book a demo.

FAQs

What are the key compliance deadlines for SB 253?

CARB must adopt implementing regulations by January 1, 2025; companies must submit their first Scope 1 and 2 emissions disclosures in 2026, Scope 3 disclosures begin in mid‑2027 (within 180 days of the Scope 1 and 2 report), and by 2030 all disclosures require reasonable assurance including Scope 3.

When are companies required to submit their first SB 261 climate risk report?

The first SB 261 risk report is due by January 1, 2026, and subsequent reports are required every two years thereafter.

What assurance requirements apply to SB 253 emissions reporting?

From 2026, Scope 1 and 2 emissions must undergo limited third‑party assurance; by 2030, reasonable assurance is required for Scope 1, 2 and limited assurance begins for Scope 3 disclosures.

Is there enforcement relief during the initial compliance year?

Yes. CARB has stated that it will not enforce penalties in the first reporting year provided companies demonstrate a “good faith effort” to prepare disclosures.

What happens if CARB misses the January 1, 2025 regulation adoption deadline?

CARB missed that statutory deadline and now expects to publish final regulations in 2026 after additional workshops; however, statutory reporting deadlines remain unchanged.

What is the mid‑year 2027 deadline for Scope 3 reporting under SB 253?

Scope 3 emissions must be reported beginning in mid‑2027—specifically within 180 days following the submission of Scope 1 and 2 disclosures made in 2026.

What is the 2030 assurance requirement for SB 253 and SB 261?

By 2030, Scope 1 and 2 emissions reporting must undergo reasonable third‑party assurance, and limited assurance becomes mandatory for Scope 3 emissions; SB 261 does not require formal assurance.

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