Updates on the California Air Resources Board SB 253/261 Climate-Related Legislation

On Thursday, August 21, 2025, the California Air Resources Board (CARB) hosted a public workshop on Senate Bills (SB) 253 and 261, also known by CARB as the 200’s. The workshop provided important clarification on California’s corporate climate disclosure laws, also known as the Climate Accountability Package. For more information about the laws’ applicability, timeline, and enforcement, refer to ALL4’s previous blog on this topic. CARB is currently developing implementation regulations for these laws and is seeking public feedback. The update below summarizes CARB’s announcements and outlines the next steps to help companies doing business in California prepare for compliance.

Key Takeaways from the August 21^st Workshop:

• Applicability of the Climate Accountability Package
  • SB 253 applies to entities (public or private) with $1 billion+ in annual revenue doing business in California.
  • SB 261 applies to entities with $500 million+ in annual revenue doing business in California.
  • “Doing business in California,” and “revenue,” remain under review, with CARB continuing to request stakeholder input.
• SB 253 – The Climate Corporate Data Accountability Act
  • CARB has proposed a submittal deadline of June 30, 2026 for reporting Scope 1 and Scope 2 greenhouse gas (GHG) emissions from Fiscal Year 2025 data, with limited assurance.
  • The draft report format template is to be released for public comment in September 2025.
  • The annual CARB fee for SB 253 is proposed to be set at $3,106 per year, per reporting entity.
  • Scope 3 GHG emissions reporting timelines will be established by CARB through a future rulemaking.
  • Scope 1, Scope 2, and Scope 3 GHG emissions reporting may be consolidated at the parent company level.
• SB 261 – Climate-Related Financial Risk Disclosure
  • The reporting deadline for the climate-related risk assessment disclosure remains January 1, 2026, for subject entities.
  • SB 261 does not specify Calendar Year or Fiscal Year data. CARB states that covered entities should use the most recent or best available data for their first report.
  • Reporting entities must publish disclosures on their websites and submit them to CARB’s public docket, which will open on December 1, 2025. On that date, CARB will begin posting a docket where entities must provide the location of their public link to their initial climate-related financial risk report under this program. The docket will remain open until July 1, 2026, serving as a centralized, transparent resource for the public to access all climate-related financial risk reports.
  • The annual CARB fee for SB 261 is proposed to be set at $1,403 per year, per reporting entity.
  • Scenario analysis will not be required in Year 1 reporting; qualitative analysis will be sufficient in later years, though quantitative analysis is encouraged.
  • GHG emissions reporting will not be required in Year 1.
• Fee Structure and Applicability
  • The CARB fees for SB 253 and SB 261 are cumulative for entities subject to both laws.
  • The CARB fees are to be paid annually per reporting entity (even though SB 261 reporting is biennial).
  • The CARB fees will be adjusted for inflation as necessary.
• Assurance Standards
  • CARB is working to finalize the assurance requirements in the rulemaking process.
  • The assurance standards under consideration include International Standard on Sustainability Assurance (ISSA) 5000, AccountAbility AA1000, the International Organization for Standardization (ISO) 14060 family of standards, and Association of International Certified Professional Accountants (AICPA).
  • Stakeholder feedback on assurance standards is actively being solicited by CARB.

Enforcement and Compliance

• CARB will exercise enforcement discretion in 2026, recognizing the challenges of early implementation. Entities that demonstrate good-faith efforts to comply will not face penalties for incomplete reporting.
• In subsequent years, CARB will provide additional enforcement guidance as regulations mature.

Next Steps for Businesses

1. If you need a refresher on CARB’s Climate Accountability Package, go back and review ALL4’s blog from earlier this year for clarification and guidance.
2. Companies should determine whether either of California’s climate laws apply to them.
3. Companies subject to SB 253 should begin collecting Scope 1 and Scope 2 GHG emissions data for Fiscal Year 2025 now to meet the June 30, 2026 reporting deadline.
4. Companies subject to SB 261 should prepare their first climate-related financial risk report by January 1, 2026 focusing on the most recent or best available data for their first report.
5. Entities should anticipate annual CARB fees ($3,106 per year for SB 253; $1,403 per year for SB 261), with adjustments for inflation.
6. Companies are encouraged to provide feedback on definitions, assurance standards, and draft report formats utilizing CARB’s public comment solicitation board.

How ALL4 Can Help

ALL4 is closely monitoring CARB’s implementation of SB 253 and SB 261, as well as developments in GHG emissions disclosure, climate-risk reporting, and enforcement guidance, to help businesses prepare for California’s climate-accountability requirements. Our team of sustainability experts can support your company by developing GHG emissions inventories and conducting climate-related risk assessments to ensure accurate and compliant disclosure.

For questions about these legislations, please contact James Giannantonio, Managing Consultant (jgiannantonio@all4inc.com) or Daryl Whitt, Technical Director (dwhitt@all4inc.com).