On October 23, 2026, the California Air Resources Board (CARB) held an informational public board meeting to discuss updates regarding the California Corporate Greenhouse Gas Reporting Program being developed under the Climate Corporate Data Accountability Act [Senate Bill (SB) 253]. Because this was an informational meeting, CARB agency staff did not propose new regulations, but agency staff did provide an update to the CARB governing body members (Board) on the current regulation and the proposed upcoming rulemaking for future reporting.
Background
As a reminder, on October 12, 2026, the Office of Administrative Law (OAL) approved the Initial Regulation covering the first-year reports due on November 10, 2026. SB 253 is codified in Health and Safety Code (HSC) 38532, requiring qualifying business entities with annual revenues exceeding $1 billion dollars and that do business in California to annually disclose their greenhouse gas (GHG) emissions as part of this reporting program.
On July 21, 2026, CARB held a public workshop to support the development of the rulemaking, explaining CARB’s proposed approach for Scope 3 emissions reporting, which is set to commence starting in 2027. CARB also held six sector-specific listening sessions. Through both the listening sessions and the July workshop, CARB received numerous comments on its proposed Scope 3 emissions reporting approach.
October 2026 Board Meeting
The October 2026 Board meeting started with CARB staff giving an overview presentation on the status of the Initial Regulation and the engagement and feedback received in the subsequent workshops and listening sessions. Four expert panelists then presented on their respective topics followed by Board discussions, questions, and comments. The meeting concluded with a closed Board session and public comment on the topic.
Staff Presentation
Staff started with a brief overview of the regulation, requirements, and deadlines, a summary of other existing reporting programs globally, and a refresher on GHG reporting scopes (Scope 1, Scope 2, and Scope 3 emissions). Staff discussed the legislative direction included in the HSC § 38532 regulation and described the regulatory drafting and implementation process to date. Staff also highlighted the differences that will be coming with the subsequent regulation and the differences from the Initial Regulation – specifically, mandatory detailed annual Scope 1 and Scope 2 reporting, mandatory assurance requirements, and the addition of Scope 3 reporting. CARB staff also described the high level of engagement with stakeholders in the listening sessions, workshop, and the various feedback and comments received on the proposed Scope 3 reporting, and the key themes identified from this public engagement are:
- Quantification Methods: Stakeholders wanted flexibility for recalculation and base-year requirements, and more flexible data reporting methods.
- Scope 3: Stakeholders wanted clearer guidance for entities to select which Scope 3 categories to report, in accordance with the GHG Protocol guidance. Specifically, their concerns included CARB’s proposed approach to designate the five categories which are not “materially relevant” to all industries and companies, and that assigning categories to report on contradicts the flexibility offered by the GHG Protocol.
- Interoperability: Emphasis that companies want the ability to comply using reports created for other jurisdictions or agencies rather than a new, California-specific report.
- Reporting Logistics: Several requests for tools or other abilities to leverage existing data from other reports already developed and submitted to other agencies or jurisdictions.
- Assurance: Received requests for clarification on assurance reporting and support for standards and accreditations for verifications.
Throughout the Board meeting, staff continually emphasized the struggle and “healthy conflict” between CARB’s requirement and mandate to prepare legislation for reporting entities to report using the GHG Protocol, and the GHG Protocol’s inherent flexibility it offers to entities in what is required for reporting.
Expert Panelist Presentations
The Board also heard from four expert panelists during their presentations, and subsequent Board questions and comments. The panelists consisted of:
- Catherine Atkin from Carbon Accountable, who presented on the context and background of the authorizing legislation as one of the key companies working with the senators to pass SB 253. Catherine also provided context on the SB 253 requirements, the principles it was built from, and the support and “on ramps” the regulation provides for Scope 3 reporting.
- Tim Mohin, CEO of the GHG Protocol, who presented on the GHG Protocol, its incorporation in international standards and reporting programs and partnerships with the International Organization for Standardization (ISO), and how the GHG Protocol can be used for the SB 253 climate disclosure reporting, as well as discussing upcoming changes to standards forthcoming in Q2 2027, with final publication scheduled for 2028.
- Chris Shimoda from the California Council for Environmental and Economic Balance (CCEEB), gave an industry and business perspective and feedback on this regulation, the reporting burden for industry, and important considerations for CARB in the subsequent rulemaking.
- Maggie Delmas from the University of California, described the state of corporate sustainability disclosure from evaluating global trends, voluntary disclosure programs, and large companies already reporting under other programs.
Board Discussion
After the staff and expert panelist presentations, the Board asked follow-up questions to staff and the panelists regarding the presentations, proposed subsequent rulemaking, and considerations for that future rulemaking.
Several questions revolved around the topic of Scope 3 categories. The GHG Protocol allows for the flexibility for companies to select which categories are materially relevant to their operations, and to report based on those categories. In the proposed Scope 3 reporting approach from the July 2026 workshop, CARB staff had proposed to require all companies to report on five specific categories of the 15 total Scope 3 categories. However; while CARB is mandated to prepare a regulation that companies must comply with, it must also be based on the GHG Protocol, and CARB is evaluating how to reconcile these two directives. The Board also posed multiple questions regarding the burden and timeline required for preparing these reports and calculating Scope 3 emissions to get a better understanding.
The key takeaway is that CARB staff declared that it is taking the feedback received regarding the flexibility of the GHG Protocol for choosing relevant Scope 3 categories and is still working on the proposed rulemaking but plans to have another workshop to continue the dialogue.
Conclusion and Next Steps
For 2026 reporting, the deadline for the first year of submittal is coming up on November 10, 2026, and CARB has already received numerous reports from business entities for the Initial Rulemaking. ALL4 will continue to monitor CARB progress as it schedules its future workshop(s) and develops the regulation for 2027 and subsequent reporting years and the associated Scope 3 and other reporting requirements.
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 or Board meeting, please reach out to Corey Prigent at cprigent@all4inc.com.
