California's First Corporate Climate Deadline Was Already Moved Before It Arrived

Regulators deferred the SB 253 reporting date to November back in June, weeks before today's original date came around

California's first corporate climate disclosure deadline was due to fall today. In practice, it did not, because the state's environmental regulator moved the date seven weeks ago and told covered companies not to treat 10 August as operative.

In a bulletin issued on 24 June, the California Air Resources Board confirmed it was deferring the first Scope 1 and Scope 2 emissions reporting deadline under the Climate Corporate Data Accountability Act, known as SB 253, from 10 August to 10 November.

The regulator framed the extra three months as time for reporting entities to work with certainty once a revised version of the underlying regulation is formally approved, rather than filing against a date the rule itself was still being rewritten around.

Why the Date Kept Moving

CARB adopted its initial regulation on 26 February, setting the fee structure, defining which companies count as reporting entities, and fixing 10 August as the first-year deadline for Scope 1 and Scope 2 disclosures. That regulation went to the Office of Administrative Law for final sign-off on 20 May.

Five weeks later, CARB withdrew it, saying it needed to make limited clarifying changes to certain requirements, including how insurance companies are treated. Because amending an already-submitted regulation restarts the review clock, CARB pushed the reporting deadline back in step, so companies would not be bound to a date tied to a rule still being edited.

What Companies Are Actually Being Told

Compliance advisers have treated 10 November as the working deadline since the June bulletin landed.

Watershed's guidance to reporting companies has told them plainly to act now against that date, and law firms including Sidley, White and Case, Davis Polk and Proskauer issued near-identical client alerts within days of the announcement.

CARB has separately said it will exercise enforcement discretion for good faith first year submissions, and companies that were not already collecting emissions data as of December 2024 can file a non-collection statement instead of a full report for this cycle.

The clarifying changes to the regulation, including the revised deadline, are due for a fifteen day public comment period before CARB resubmits the package to the Office of Administrative Law.

The Rule Nobody Is Contesting

What has not moved is the underlying obligation. Companies organised under United States law, doing business in California, and reporting more than a billion dollars in annual revenue still have to disclose Scope 1 and Scope 2 emissions for 2026, with Scope 3 following in 2027.

SB 253's companion law, SB 261, requiring biennial climate risk disclosure from companies over five hundred million dollars in revenue, runs on an entirely separate timeline: its own deadline remains unenforced after a Ninth Circuit injunction granted in November 2025, with CARB waiting on the outcome of that appeal before setting a new date.

Why California Rules Rarely Stay Local

California's economy is large enough that its rules rarely stay contained within state lines.

Companies with no California headquarters but customers or operations there, including apparel and textile firms that manufacture abroad and sell into the state, have spent the year building reporting systems around a date that has already moved once and could move again if the clarifying regulation runs into delay.

That pattern, disclosure requirements that shape supply chain behaviour before the underlying rule is finalised, is one apparel brands have grown used to watching from the European Union as well.

Key Takeaways

1. CARB confirmed in a 24 June bulletin that it is deferring SB 253's first Scope 1 and Scope 2 reporting deadline from 10 August to 10 November 2026.
2. The deferral followed CARB's withdrawal of its adopted regulation from the Office of Administrative Law to make clarifying changes.
3. A fifteen day public comment period on those changes is expected before the regulation is resubmitted for final approval.
4. Companies already collecting emissions data as of December 2024 are still expected to file by the new date; others may submit a non-collection statement.
5. SB 261, the companion climate risk law, remains unenforced pending a separate Ninth Circuit appeal.