The California Air Resources Board (CARB) will hold a virtual public workshop to support the development of the California Corporate Greenhouse Gas Reporting Program and the Climate-Related Financial Risk Disclosure Program, authorized by Senate Bills (SB) 253 (Wiener, 2023) and SB 261 (Stern, 2023), as amended by SB 219 (Wiener, 2024; amending Health & Safety Code (HSC) §§ 38532 and 38533).

The workshop will begin with an update from CARB staff on the development of the programs under HSC §§ 38532 and 38533. Discussion will include the preliminary list of covered/reporting entities published on September 24, 2025, and efforts to refine this list to inform development of the initial regulation. To further inform compliance and help determine which entities are subject to each statute, staff will also present proposed updates to definitions and exemptions. In addition, staff will discuss the scope of the initial regulation, which is limited to establishing the fee component and associated definitions, and the first reporting deadline for HSC § 38532.  

The workshop will be held virtually: 

Date:          Tuesday, November 18, 2025 
Time:          9:30 am – 12:30 pm (Pacific Time) 

REGISTER FOR ZOOM SESSION (https://us06web.zoom.us/webinar/register/WN_C73cKag_TIWSOMqqvccCuQ#/registration)

Status of Initial Regulation 

CARB is currently developing a proposed regulation for Board consideration in the first quarter of 2026 that will both establish a fee component and set the first reporting deadline under HSC § 38532. Given that both HSC §§ 38532 and 38533 authorize CARB to establish fees to recover program implementation costs, this rulemaking proposes to include provisions to establish the fee structure necessary to administer these programs. In addition, the rulemaking also proposes to set the first reporting deadline for HSC § 38532. While the statute requires reporting entities to report Scope 1 and Scope 2 GHG emissions in 2026, it does not specify a particular reporting date. Under this initial proposed regulation, entities subject to HSC § 38532 would be required to report Scope 1 and Scope 2 emissions on the proposed deadline.

This initial rulemaking does not affect the January 1, 2026 reporting deadline under HSC § 38533. Covered entities must prepare and publish their first climate-related financial risk report on their website on or before January 1, 2026, and biennially thereafter. Because this deadline is established in statute, it may only be changed by legislation. To support transparency and public access, CARB will open a public docket on December 1, 2025, for covered entities to submit a public link to their report. The docket will remain open until July 1, 2026, and will provide a centralized location for accessing submitted reports for investors and consumers. For more information and guidance regarding first-year reporting under HSC § 38533, see CARB’s Frequently Asked Questions document and Climate-Related Financial Risk Report Checklist, available on CARB’s webpage (https://ww2.arb.ca.gov/our-work/programs/corporate-ghg-reporting/resources). 

Background 

The California Corporate Greenhouse Gas Reporting Program, authorized by Senate Bill (SB) 253 (Wiener, 2023) is being developed by the California Air Resources Board (CARB) and will require business entities formed under the laws of California, the laws of any other state of the United States or the District of Columbia, or under an act of the Congress of the United States, with total annual revenues in excess of one billion dollars ($1,000,000,000) that do business in California (“reporting entities”) to annually disclose their Scope 1, Scope 2 and Scope 3 emissions for the prior fiscal year. The initial (first-year) annual emissions disclosures in 2026 are required to address Scope 1 and Scope 2 emissions with third-party limited assurance requirements, and in subsequent years (beginning in 2027) must include Scope 3 emissions. The Climate Related Financial Risk Disclosure Program authorized by SB 261 (Stern, 2023) also applies to both public and private U.S. companies that do business in California with annual revenues in excess of $500 million. This program is also currently under development by CARB and will require companies to publish biennial climate-related financial risk reports. SB 219 introduced amendments to parts of SB 253 and SB 261, including adjustments to regulatory timelines, the timing for reporting Scope 3 emissions, fee payments, and other provisions.