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    SB 253 Explained: California's Climate Disclosure Law for Scope 1, 2 and 3 Emissions (2026)

    SB 253 requires US public and private companies with more than $1 billion in annual revenue that do business in California to report Scope 1 and 2 emissions each year, then Scope 3 from 2027, using the GHG Protocol. The first Scope 1 and 2 reports are due by 10 November 2026.

    Last updated 2 November 2026 · By Ella Sustainability Team

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    What is SB 253?

    SB 253, the Climate Corporate Data Accountability Act, is a California law passed in 2023 and amended by SB 219 in 2024. It requires large companies to disclose their greenhouse gas emissions to the California Air Resources Board (CARB) every year. It applies to private companies as well as listed ones, which is what makes it different from most disclosure rules. Many large privately owned US businesses that have never published a carbon footprint now have to report one. CARB's Initial Regulation, approved by California's Office of Administrative Law on 12 October 2026, sets the first reporting deadline, a shared applicability framework for SB 253 and SB 261, and annual fees. A second rulemaking will cover Scope 3, assurance and reporting formats from 2027.

    Who has to report under SB 253?

    A company is in scope if it meets all three tests: 1. It is a partnership, corporation, LLC or other business entity formed under US federal or state law 2. It has total annual revenue above $1 billion, counting all revenue, not only California sales 3. It does business in California Under CARB's final rule, revenue is tested on the lesser of the entity's two prior fiscal years, and intercompany transactions within a combined reporting group are excluded. CARB's proposal tied doing business in California to the sales tests in the state's tax code (Revenue and Taxation Code section 23101), so even modest California sales can bring a company in. Check the threshold with your tax and legal teams early. CARB's proposed exclusions cover tax-exempt nonprofits, entities regulated as insurers, government-owned entities, businesses that only sell wholesale electricity and businesses whose only California presence is payroll.

    SB 253 deadlines and requirements at a glance

    The table summarises what is required and when, based on the statute and CARB's 2026 rules.
    SB 253 deadlines and requirements at a glance
    RequirementWhat it meansWhen
    Scope 1 and 2 reportDirect emissions and purchased energy emissions for the prior fiscal yearFirst report due 10 November 2026, then annually
    Scope 3 reportValue chain emissions, with no materiality threshold in the statuteFrom 2027; timing set by CARB's second rulemaking
    MethodologyGHG Protocol standards and guidanceEvery report
    Limited assurance, Scope 1 and 2Independent third-party assuranceRequired from 2026 under the statute; CARB accepts 2026 reports without it
    Reasonable assurance, Scope 1 and 2Higher level of assuranceFrom 2030
    Scope 3 assuranceLimited assuranceFrom 2030
    Annual feeSeparate SB 253 and SB 261 feesNotices by 10 December each year, payable within 60 days
    Maximum penaltyAdministrative penalty for non-complianceUp to $500,000 per reporting year

    What CARB expects for the first report in 2026

    CARB is using enforcement discretion for the first cycle. Its September 2026 guidance says companies can report prior-year Scope 1 and 2 emissions based on information they already had or were collecting when CARB's December 2024 notice was issued, whether or not that data has received limited assurance. Companies that were not collecting this data are not expected to submit Scope 1 and 2 figures in 2026 only. CARB asks them to send a statement of non-reporting on company letterhead before 10 November 2026, through its 2026 Report Intake Platform or by email. CARB also encourages companies to explain their organisational boundaries, methodologies, data sources, global warming potential values and emission factors. That is voluntary this year. It will not stay voluntary once assurance becomes routine.

    Scope 3 under SB 253

    Scope 3 reporting starts in 2027 and covers all relevant categories of value chain emissions. The statute gives some protection while methods mature: 1. Scope 3 misstatements made with a reasonable basis and disclosed in good faith are not penalised 2. Between 2027 and 2030, CARB may only penalise Scope 3 for failing to file, not for the numbers themselves 3. Limited assurance on Scope 3 is expected from 2030 For most service businesses, purchased goods and services, business travel and employee commuting dominate Scope 3. These are also the categories where companies rely most on estimates. Our guide to the 15 Scope 3 categories explains each one.

    How to get ready for SB 253

    Reporting is in arrears, so the data you collect in 2026 and 2027 is the data you will report and, from 2030, have assured. A practical order of work: 1. Confirm whether you are in scope, including the California sales test and the two-year revenue rule 2. Set your organisational boundary and decide how shared services and acquisitions are treated 3. Move Scope 1 and 2 from spreadsheets to source documents: utility bills, fuel cards, meter data 4. Map Scope 3 categories and replace the biggest estimates with activity or supplier data 5. Record a source and emission factor against every number so an assurer can trace it 6. Run a dry-run assurance review a year before you need it

    Our view: SB 253 is a data collection problem

    Most companies we speak to that are approaching SB 253 already calculate a footprint somewhere. What they lack is a repeatable way to get the underlying data from facilities managers, finance, fleet and travel teams, broken down by entity, with evidence attached. That is the part an assurer will test, and it is the part spreadsheets handle worst. Ella is AI-native carbon accounting software built as an agent. It sets your boundary from how the business operates, tags data by entity, sends collect links to the people who hold bills and invoices, chases missing responses and keeps a source on every number. Scope 1, 2 and 3 are calculated automatically, with expert support from Ella's team.

    How Ella helps

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    Frequently Asked Questions

    What is SB 253?

    SB 253, the Climate Corporate Data Accountability Act, is a California law requiring US companies with more than $1 billion in annual revenue that do business in California to report Scope 1 and 2 emissions annually, and Scope 3 emissions from 2027, using the GHG Protocol.

    When is the first SB 253 report due?

    CARB's Initial Regulation, effective 12 October 2026, sets 10 November 2026 as the deadline for the first Scope 1 and 2 reports covering the prior fiscal year. Scope 3 reporting begins in 2027.

    Does SB 253 apply to private companies?

    Yes. SB 253 applies to public and private US business entities that meet the $1 billion revenue threshold and do business in California.

    What is the SB 253 penalty?

    Administrative penalties are capped at $500,000 per reporting year. For Scope 3, between 2027 and 2030 penalties apply only for failing to file, and good-faith misstatements with a reasonable basis are not penalised.

    Does SB 253 require assurance?

    Yes. The statute requires limited assurance on Scope 1 and 2 from 2026 and reasonable assurance from 2030, with limited assurance on Scope 3 from 2030. CARB will accept 2026 reports without assurance.

    How is the $1 billion revenue threshold measured?

    Total revenue, not just California sales. Under CARB's final rule, revenue is tested on the lesser of the two prior fiscal years, excluding intercompany transactions within a combined reporting group.

    What if we were not collecting emissions data before December 2024?

    For the 2026 cycle only, CARB does not expect Scope 1 and 2 data from companies that were not collecting it. It asks them to submit a statement of non-reporting on company letterhead by 10 November 2026.

    What software helps with SB 253 reporting?

    Carbon accounting software such as Ella collects Scope 1, 2 and 3 data from the people who hold it, tags it by entity, calculates emissions with the GHG Protocol and keeps an audit trail for assurance.

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