CARB Opens SB 253 Reporting Intake: The Platform Provides More Than CARB's Guidance

On September 1, 2026, the California Air Resources Board (“CARB”) issued guidance for the first reporting cycle under California’s Climate Corporate Data Accountability Act (“SB 253”) and opened a voluntary online intake platform for submitting Scope 1 and Scope 2 greenhouse gas emissions reports. 

The new materials answer several practical questions that have remained open: what companies may submit, how reports will be filed, how CARB will handle entities without emissions data, and how consolidated reporting and fee invoicing will work.

CARB continues to use November 10, 2026 as the first-year reporting deadline. The deadline, however, appears in CARB’s proposed Initial Regulation, which still requires approval by the California Office of Administrative Law (“OAL”). The guidance itself is framed to apply "if approved by the Office of Administrative Law," and CARB's modified regulatory text, which formalizes the November 10 date, completed its 15-day comment period on August 11, 2026; as of the guidance's issuance, OAL approval had not occurred. Companies should therefore plan against November 10 while monitoring finalization on CARB’s rulemaking page.

A separate CARB-formatted report is not required for 2026

CARB confirms that reporting entities may submit:

• an existing annual report that includes Scope 1 and Scope 2 emissions;
• existing Scope 1 and Scope 2 data reported through another regulatory program or voluntary initiative; or
• CARB’s draft Scope 1 and Scope 2 reporting template, which remains optional.

Reports may be uploaded through the voluntary intake platform, available through CARB’s Climate Disclosure webpage, or submitted to CARB via email.

First-year enforcement discretion remains broad—but temporary

CARB will accept Scope 1 and Scope 2 figures derived from information a reporting entity already possessed or was collecting when CARB issued its December 5, 2024 Enforcement Notice. CARB will accept those submissions whether or not limited assurance has been obtained.

An entity that was neither collecting nor planning to collect such data at that time is not expected to submit emissions data by November 10 deadline; CARB instead requests a statement on company letterhead explaining that data-collection posture. This is first-cycle discretion, not a continuing exemption: CARB expressly limits the guidance to 2026 reporting. 

The platform is a fee register — organized entity by entity

The platform states that all reporting entities covered by the Initial Regulation will be assessed a fee regardless of whether they submit emissions data or a statement of non-reporting.  Under CARB’s proposed regulatory text, invoices would be issued on or before December 10, 2026, with payment due within 60 calendar days of the invoice date, and the fee attaches to each reporting entity: a consolidated report does not appear to collapse multiple qualifying entities into a single assessment, though a parent may pay the combined amount.

The platform's structure operationalizes a point the guidance leaves implicit: there is no "ABC Group and its subsidiaries" line. The form asks up front how many reporting entities the submission covers and whether fees will be paid combined or individually, and then opens a separate block for each entity, requesting its full legal name as filed on tax forms, its own identifiers (federal EIN, California Corporation Number, or Secretary of State file number), and its California Principal Business Activity code from its state tax filing. The entity-by-entity block may be repeated as many times as needed to cover each reporting entity in the group. Per CARB's tutorial, a single submission may mix emissions reports for some entities with statements of non-reporting for others.

In other words, consolidated reporting is accepted; consolidated identification is not.  Completing those blocks is, functionally, entity-by-entity self-identification as reporting entities, which means corporate groups must resolve, before the form is filled out, both their consolidated reporting perimeter and the applicability analysis for every entity in the family that independently satisfies CARB's criteria, not just the parent.

Uploaded reports will be public

The platform states that uploaded emissions reports and statements of non-reporting will be made public and instructs companies not to include confidential business information. The submission workflow contains no confidentiality designation or redaction mechanism, so any confidential content must be removed before uploading it to the platform. Companies reusing an existing sustainability report or regulatory filing should also confirm it covers the appropriate reporting period and perimeter.

The 2026 process is intentionally flexible, but the positions taken through the platform may become not only public, but may be uploaded to a database and eventually compared. The flexibility does not eliminate the need to make—and document—entity-level applicability, reporting-boundary, public-disclosure, and fee decisions before November 10.