The California Air Resources Board has issued a set of Frequently Asked Questions related to the development of California's Corporate Greenhouse Gas Reporting Program.

The Corporate GHG Reporting Program, authorized by Senate Bill 253, is being developed by the CARB and will require business entities formed under the laws of California, the laws of any other state of the United States or the District of Columbia, or under an act of the Congress of the United States, with total annual revenues in excess of $1 billion dollars that do business in California, to annually disclose their scope 1, 2, and 3 emissions for the prior fiscal year.

Reporting entities must report Scope 1 and Scope 2 GHG emissions in 2026, on a date to be set by CARB through the regulatory process, covering the prior fiscal year. Scope 3 emissions reporting begins in 2027, covering the prior fiscal year.

In addition, the Climate Related Financial Risk Disclosure Program authorized by SB 261 also applies to both public and private U.S. companies that do business in California with annual revenues in excess of $500 million. This program is also currently under development by CARB and will require companies to publish biennial climate-related financial risk reports.

For the Climate-related Financial Risk Reporting Program, covered entities must prepare and publish their first climate-related financial risk report by January 1, 2026, and biennially thereafter. On December 1, 2025, CARB will post a public docket for covered entities to post the location of their public link to their first climate-related financial risk report. CARB will keep this public docket open until July 1, 2026.

Both programs are implemented under the California Health and Safety Code, are intended to support transparency for consumer and investor decisions.

CARB's announcement states it will endeavor to design these programs in a way that minimizes burdens from implementation and compliance, particularly for companies that are already required to report this data in other jurisdictions.