CARB Defers SB 253 Scope 1 & 2 Reporting Deadline by Three Months

On June 24, 2026, the California Air Resources Board (“CARB”) announced it will push the initial SB 253 Scope 1 and Scope 2 greenhouse gas (“GHG”) emissions reporting deadline back three months — from August 10, 2026 to November 10, 2026 — to give reporting entities more time to absorb the final rules. The deferral will be formalized through a limited rulemaking amendment to CARB’s Initial Regulation (Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation) once cleared by the Office of Administrative Law (“OAL”).

Background

The California Climate Corporate Data Accountability Act — SB 253 — requires U.S.-based companies with over $1 billion in annual revenue “doing business” in California to annually disclose their Scope 1, Scope 2 and Scope 3 GHG emissions. On February 26, 2026, CARB approved its Initial Regulation implementing SB 253 and its companion law, the California Climate-Related Financial Risk Reporting Act (“SB 261”). As we have previously reported, SB 261 remains subject to a preliminary injunction issued by the Ninth Circuit, though the SB 253 reporting requirements remain in effect.

Key Developments

CARB pulled the Initial Regulation back from OAL review to make targeted amendments — chief among them the three-month deadline extension. A 15-day public comment period will follow before CARB resubmits the revised regulation to OAL for final approval. The new November 10, 2026 reporting deadline is intended to give companies a clearer view of the final regulation before initial Scope 1 and Scope 2 reports are due.

This is not a pause across the board: The deferral is limited to Scope 1 and Scope 2. Scope 3 reporting remains on track for 2027. As we reported in April 2026, CARB has separately launched rulemaking to develop Scope 3 reporting regulations, including proposals regarding organizational boundary-setting, accounting methods, emissions factors, and phased reporting options.

Takeaways

Three extra months is a relief, but it is not a pass to stand down. The California climate reporting landscape remains unsettled: CARB’s rulemaking is still in flux, OAL has yet to give final approval, and the Scope 3 clock is ticking toward 2027. It also remains to be seen whether the Ninth Circuit will enjoin SB 253 as it has SB 261 — companies subject to SB 253 should, therefore, continue to prepare as though the November deadline will hold. V&E is monitoring all of these developments closely, including the forthcoming 15-day comment period on CARB’s amendments, and will provide updates as California’s regulatory picture comes into focus.

We will continue to track developments related to California’s climate reporting laws. Please reach out to your Vinson & Elkins team to discuss these matters and their implications for your business.

This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.