CARB has released guidance for the first year of reporting under SB 253, along with a voluntary 2026 Report Intake Platform. Both address the initial Scope 1 and Scope 2 emissions reports due November 10, 2026.
The guidance does not add requirements. It narrows the decisions your team has to make in the next nine weeks. Here are the five that matter.
1. Decide Which of Two Paths Applies to Your Company
CARB's first-year enforcement discretion splits reporting entities into two groups, and the dividing line is a single date: December 5, 2024.
If your company already had, or was collecting, Scope 1 and Scope 2 data when CARB issued its Enforcement Notice, you submit that data — whether or not it received limited assurance.
If your company was not collecting and was not planning to collect that data, CARB does not expect emissions data from you this cycle. Instead, CARB recommends submitting a statement of non-reporting on company letterhead by November 10, confirming that position as of the Enforcement Notice date.
Both paths require an action by November 10. Neither path is "do nothing."
2. Choose a Format. CARB Accepts Three.
For entities reporting emissions, the guidance identifies three acceptable formats:
- An existing annual report containing Scope 1 and Scope 2 emissions
- Existing Scope 1 and Scope 2 data already reported to another program or voluntary initiative
- CARB's draft Scope 1 and Scope 2 reporting template, use of which remains voluntary
CARB encourages, but does not require, supporting detail where available: methodologies, data sources, global warming potential values, emission factors, organizational boundaries, disaggregated emissions data, and assumptions. That detail is optional this year. It is also the record you will rely on when 2027 requirements arrive — worth capturing now.
3. Document Your Scope 2 Emission Factor Source
Because EPA's eGRID 2024 release has not arrived on its usual timeline, CARB confirmed that the Initial Regulation does not require a particular emission-factor dataset for 2026. Entities may use the most recent official EPA release, eGRID 2023; the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative using EPA's publicly available source code; or another credible emission-factor source. CARB encourages companies to identify the emission factors they used and where those factors came from.
4. Assurance Can Wait. The Fee Cannot.
SB 253 provides for limited assurance beginning in 2026, but CARB confirmed that, consistent with first-year enforcement discretion, it will accept 2026 submissions whether or not assurance has been obtained.
The fee is separate. CARB states that all reporting entities will be assessed a fee and should provide invoicing contact information regardless of reporting status. Invoices will be sent on or before December 10, 2026, with payment due within 60 calendar days. Companies filing a statement of non-reporting still need an invoicing contact on record.
The voluntary intake platform or emailing CARB directly are the best ways to provide that information and to submit a report or statement of non-reporting. The platform also supports consolidated reporting across parent and subsidiary entities, including an indication of whether fees will be paid together or individually.
5. Route the Submission Through Legal Before It Goes Out
The intake platform states that all emissions reports and statements of non-reporting uploaded through it will be made public, and instructs entities not to include confidential business information in uploaded reports. CARB's guidance also permits submission by email, but does not separately address public availability or the treatment of confidential information for that channel.
That is a disclosure decision, not an administrative one. Confirm what your submission contains, and which channel it goes through, before November 10.
Looking Past the First Cycle
CARB is explicit that this guidance applies only to the 2026 reporting cycle. Requirements for 2027 and beyond are being developed through a second rulemaking. The guidance does not impose requirements beyond the statute and the Initial Regulation, does not constitute legal advice, and reflects CARB's enforcement discretion during the transition period.
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