Yesterday, CARB announced a public hearing for February 26, 2026, to consider the proposed Climate Data and Financial Risk Reporting Fee Regulation. The proposed regulation is accompanied by this Staff Report. CARB anticipates that the Notice of Public Hearing will be formally published on December 26, which will launch a 45-day public comment period that will end on February 9, 2026. Reportedly in light of the holiday season and the strong interest, CARB is allowing extra time for public review of the materials before the start of the 45-day comment period, and will update the rulemaking package if any revisions are made before the formal publication.
Relatedly, CARB posted an updated slide deck on November 21 following its November 18 workshop that includes among the proposed exclusions and exemptions a business entity whose only business within California consists of wholesale electricity transactions. This proposed exemption is now included in the proposed regulation under § 96201(b).
As previously reported, subject to a carve-out for companies not collecting data or not planning to collect data at the time the December 2024 Enforcement Notice was issued, CARB is proposing a first year Scope 1 and Scope 2 emissions reporting deadline of August 10, 2026, as follows:
- If the reporting entity’s fiscal year ends between January 1 and February 1, 2026, the entity will report data from the fiscal year ending in 2026.
- If the reporting entity’s fiscal year ends between February 2 and December 31, 2026, the entity will report data from the fiscal year ending in 2025.
If any company or client of a firm that is required to report under SB 253 in 2026 will have difficulty meeting the August 10, 2026, reporting deadline, please email Randi Morrison to inform our further near-term engagement with CARB on that issue.