This afternoon, the Society submitted this member-informed comment letter in response to the California Air Resources Board’s (“CARB”) request for comments on its proposals, as outlined during its August 21, 2025, public workshop (the “August Workshop”), regarding the implementation of California’s climate disclosure legislation, Senate Bill 253 (“SB 253”) and Senate Bill 261 (“SB 261”), as amended by Senate Bill 219 (“SB 219”).
The letter provided feedback and offers recommendations on the following topics:
- Timing of greenhouse gas (GHG) emissions reporting under SB 253
- Timing of assurance under SB 253
- Definition of “doing business in California” under both SB 253 and SB 261
- Treatment of parent-subsidiary relationships under both SB 253 and SB 261
- Enforcement relief for the initial reporting under both SB 253 and SB 261
- Rulemaking process and timeline for both SB 253 and SB 261
Thank you to Sullivan & Cromwell’s June Hu, who has continued to partner tirelessly and strategically with the Society since the onset and throughout this rulemaking process, and all of the members of the CARB working group who participated in this important effort. The comment letter will serve to further inform CARB’s consideration of regulations to implement this legislation.
Access additional comment letters here and our prior submissions to CARB here.