CARB Seeks Comment on Latest GHG Reporting Program Proposals Following Public Workshop

(Bracewell) With the initial August 10, 2026, reporting deadline approaching, the California Air Resources Board (CARB) hosted its fourth public workshop on March 23, 2026, and focused on implementing the Climate Corporate Data Accountability Act’s (SB 253) greenhouse gas (GHG) emissions disclosure program.

As Bracewell has previously explained,[1] SB 253 requires US companies with total annual revenues in excess of $1 billion that do business in California to annually disclose their Scope 1, 2 and 3 GHG emissions for the prior fiscal year. As detailed further in a recent Bracewell White Paper, ESG for Directors,[2] CARB approved initial regulations for SB 253 in February[3] to further define “doing business” and calculate revenue compared to the threshold, and CARB noted that the initial reporting deadline applies only to Scope 1 and Scope 2 emissions. During the March public workshop, CARB clarified that Scope 1 and 2 templates and limited assurances are not required for initial 2026 reporting. Additionally, CARB explained that it expects to develop an updated reporting template as well as guidance regarding the 2026 reporting intake and extension request processes.[4]

The most recent public workshop was a pre-rulemaking request for feedback on CARB’s proposed GHG reporting frameworks for reporting Scope 1, 2 and 3 emissions and obtaining limited assurances for Scopes 1 and 2 in 2027 and annually thereafter.[5] CARB outlined regulatory options related to (1) organizational boundaries, (2) emission factors, and (3) accounting methods to be used when reporting GHG emissions.[6] CARB emphasized that the rulemaking process remains ongoing and that it continues to seek stakeholder input on these and other key elements of the regulatory framework, including definitions, reporting obligations and possible exemptions.

Proposed Approach for Setting Organizational Boundaries

CARB also discussed how companies set organizational boundaries, or how they determine which emissions are attributable to their direct operations versus the ones that are from indirect emissions, such as those from suppliers, investments or other upstream or downstream sources. This determination influences whether the reported emissions fall under Scope 1, 2, or 3 emissions, but does not impact the overall amount of value chain emissions.

CARB requested feedback on two approaches for setting organizational boundaries for purposes of reporting GHG emissions:

Proposed Accounting Requirements

CARB also sought feedback on the methods that companies use to quantify their Scope 3 GHG emissions once the organizational boundaries are set.

Proposed Emission Factor Datasets

Regardless of the accounting method chosen, CARB identified emissions factors as a key input.

Scope 3 Emissions: Reporting Options Under Consideration

With respect to Scope 3 emissions reporting starting in 2027, CARB outlined three potential regulatory approaches:

Scope 1 and 2 Emissions: Assurance Options Under Consideration

CARB presented a variety of proposed options for fulfilling the requirement for limited third-party assurance for Scope 1 and 2 emissions reporting, including:

CARB Continues to Welcome Public Comment

CARB is accepting public comment on all topics discussed until April 13, which can be submitted on the CARB website. Companies potentially subject to SB 253 should consider engaging in the comment process, particularly with respect to Scope 3 reporting obligations, proposed accounting methods and third-party assurance requirements, all of which may have significant operational and compliance implications. READ MORE