On September 1, 2026, the California Air Resources Board (CARB) posted guidance and resources for 2026 reporting for the Initial Regulation under the Climate Corporate Data Accountability Act [Senate Bill (SB) 253]. In July 2026 CARB published revised regulatory text that extended the reporting deadline from August 10, 2026, to November 10, 2026. The guidance also reinforces that entities are responsible for determining applicability for whether they meet the Health and Safety Code (HSC) section 38532 definition of a “reporting entity” by evaluating the revenue and whether they “do business in California.” This blog outlines what you need to know for the first reports due November 10, 2026.
Scope of 2026 Reporting
In their September 1, 2026 guidance, CARB reinforced that the agency will exercise enforcement discretion for the 2026 Report, and that reporting entities should submit the Scope 1 and Scope 2 greenhouse gas (GHG) emissions based on data already being collected at the time of the December 2024 Enforcement Notice. Facilities that were not collecting data at the time of that notice are not expected to submit Scope 1 and Scope 2 reporting data for this reporting cycle and may instead submit a statement of non-reporting.
For the 2026 reporting, CARB has stated that acceptable formats for the reporting include submitting existing Scope 1 and Scope 2 GHG emissions, submitting Scope 1 and Scope 2 data reported to other regulatory or voluntary programs, using CARB’s Draft Scope 1 and Scope 2 Template, or submittal of a statement of non-reporting.
While required under HSC section 38532 beginning in 2026, CARB has reinforced in the guidance that given the first-year enforcement discretion, the agency will accept submissions without third-party limited assurance verification.
Report Details
While CARB is accepting a wide variety of report formats for the first year of reporting, CARB is encouraging reporting entities to provide as much additional detail and context as possible to assist in the disaggregation of data to properly compare and quantify emissions. As such, the agency recommends that reporting entities provide details to qualify reported emissions numbers, including but not limited to descriptions of methodologies, data sources, global warming potential (GWP) values, emissions factors, organizational boundaries, and any additional assumptions used.
Regarding Scope 2 emission factors, CARB is aware that many entities use the Emissions & Generation Resource Integrated Database (eGRID) maintained by the United States Environmental Protection Agency (U.S. EPA) for Scope 2 emissions factors, and that U.S. EPA has not released the latest version of the eGRID data under this administration. As such, reporting entities may use the most recent official eGRID data published by U.S. EPA, or may use the dataset published by the Cornerstone Sustainability Data Initiative, which was generated from U.S. EPA’s publicly available source code, or may use alternative credible emissions factors sources.
How to Submit Reports
To streamline reporting, CARB has developed a voluntary intake platform for reporting entities to submit their 2026 Report. The use of the platform is not mandatory, and reporting entities may also choose to submit their data by emailing climatedisclosure@arb.ca.gov.
The voluntary intake platform is an online platform on which reporting entities can enter submitter and fee invoice contact information, allows for an individual to submit for multiple reporting entities at once, and provides fields to enter information about each reporting entity, with additional optional fields to provide additional facility information. The last page allows the submitter to select and upload a file for submittal to CARB and contains fields for the submitter to attach additional documentation and respond to optional questions.
Once the form has been completed and submitted, it will show a confirmation screen containing a reference number. Should a reporting entity need to amend a submission or have any questions, they may reach out to CARB via email using the reference number. CARB has also published a resource guidance video on YouTube that walks through a sample report to demonstrate the use of the intake platform.
Information reported through the intake platform will be made publicly available, except for contact information submitted for fee invoicing, which will be strictly used for billing purposes by CARB.
Conclusion and Next Steps
Reporting entities may now submit the 2026 Report via the voluntary intake reporting platform or via email.
ALL4 will continue to monitor progress as CARB develops the regulation for 2027 and subsequent reporting years and the associated requirements. For ALL4’s summary of the July 2026 Rulemaking Update and Public Workshop, the June 2026 updates article, or the February hearing and March virtual workshop updates, please review ALL4’s previous blogs.
ALL4 has staff experienced in preparing GHG emissions inventories and evaluating regulatory applicability. If you need help evaluating the rule, preparing your report, calculating Scope 1, 2, or 3 emissions, or if you have follow-up questions regarding the most recent SB 253 CARB workshop, please reach out to Corey Prigent at cprigent@all4inc.com.
