- Article Summary
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Introduction
On June 24, 2026, the California Air Resources Board announced a three-month deferral of the first SB 253 Scope 1 and Scope 2 reporting deadline, moving it from August 10, 2026 to November 10, 2026. The change is procedural rather than substantive, and the underlying reporting obligation, revenue threshold, and 2027 Scope 3 timeline remain unchanged. Companies that pause their data collection efforts in response to this delay risk being unprepared when the final regulation lands.
Key Takeaways
- CARB has proposed moving the SB 253 Scope 1 and Scope 2 reporting deadline from August 10, 2026 to November 10, 2026.
- The deferral follows CARB’s withdrawal of its Initial Regulation from Office of Administrative Law review to make limited clarifying changes.
- November 10 is a proposed date, not a final one. It still requires a 15-day public comment period and OAL approval.
- The $1 billion revenue threshold, the Scope 1 and 2 reporting requirement, and the 2027 Scope 3 start date are all unchanged.
- CARB has not disclosed what the clarifying changes will address, which is the real compliance risk companies should track.
What Did CARB Change on June 24, 2026?
CARB withdrew its Initial Regulation from Office of Administrative Law review and announced it will defer the Scope 1 and Scope 2 reporting deadline by three months, from August 10, 2026 to November 10, 2026. CARB stated two reasons for the deferral: giving reporting entities additional clarity following formal adoption of the regulation, and making limited changes to clarify certain requirements within the regulation itself.
SB 253 Reporting Timeline: From February Approval to the June Deferral
| Date | SB 253 Milestone |
|---|---|
| December 26, 2025 | CARB issues the Proposed Initial Regulation for public comment. |
| February 26, 2026 | CARB’s Board approves the Initial Regulation, establishing August 10, 2026 as the first-year Scope 1 and Scope 2 reporting deadline. |
| May 20, 2026 | CARB submits the Initial Regulation to the Office of Administrative Law, requesting an August 10, 2026 effective date. |
| June 24, 2026 | CARB withdraws the Initial Regulation from OAL review and announces a three-month deferral of the reporting deadline to November 10, 2026. |
| November 10, 2026 | Proposed New Scope 1 and Scope 2 reporting deadline, pending the 15-day comment period and OAL approval. |
Sources: Hogan Lovells, June 2026; Greenberg Traurig LLP, March 2026; Sidley Environmental, Health, and Safety Brief, June 30, 2026.
CARB issued the Proposed Initial Regulation for public comment on December 26, 2025. CARB’s Board approved that Initial Regulation implementing SB 253 and SB 261 on February 26, 2026, establishing August 10, 2026 as the first-year Scope 1 and Scope 2 reporting deadline. CARB submitted that regulation to the Office of Administrative Law on May 20, 2026, specifically requesting the August 10 effective date. Thirty five days later, on June 24, 2026, CARB withdrew the regulation from OAL review and announced the three-month deferral to November 10, 2026.
Is November 10 a Final Deadline?
| Step | Action Required Before November 10 Is Final |
|---|---|
| 1 | CARB publishes the revised regulatory text. |
| 2 | A 15-day public comment period runs on the proposed changes. |
| 3 | The Office of Administrative Law reviews and approves the resubmitted regulation. |
Sources: Fenwick, June 2026; Lexology (Jones Day), June 2026; Hogan Lovells, June 2026.
November 10, 2026 is a proposed deadline, not a settled one. Before it becomes binding, CARB must publish the revised regulatory text, complete a 15-day public comment period on the proposed changes, and resubmit the regulation to OAL for approval. Until all three steps are complete, companies should treat November 10 as a working target rather than a confirmed date.
What Has Not Changed Under SB 253?
The core SB 253 obligation is unaffected by the June 24 announcement. United States business entities with annual revenues exceeding $1 billion that do business in California must still disclose Scope 1 and Scope 2 emissions for the 2026 reporting cycle. The Scope 3 emissions reporting requirement still begins with the 2027 reporting cycle and is proceeding through a separate rulemaking track that CARB has not altered.
What Do We Still Not Know?
CARB has not disclosed which specific requirements it intends to clarify. It has not published the revised regulatory text, and as of the most recent update reviewed, it had not yet opened the 15-day public comment period it says will precede resubmission to OAL. This is the most important open question for reporting entities, because a clarifying change introduced through an expedited, condensed comment window could still affect how companies prepare their data, even though the deadline itself has moved later.

Why Companies Should Not Reset Their Compliance Clock
An extra three months and an undefined set of clarifying changes are not the same thing as a reprieve. Companies that slow down Scope 1 and 2 data collection now because the deadline moved risk facing the same compression they would have faced in August, only delayed to November, and potentially compounded by last-minute methodology clarifications. The safer posture is to treat the additional time as a buffer against uncertainty, not a reason to deprioritize the work.
How We Support Continuous Scope 1 and 2 Readiness
Regulatory timelines can shift, but the underlying task of collecting accurate Scope 1 and Scope 2 activity data does not become easier by waiting. ASUENE’s carbon accounting platform is built to keep that data collection process running continuously, so that whatever CARB’s final clarifying changes turn out to be, reporting entities are working from a complete and current emissions dataset rather than starting from scratch close to whatever the final deadline becomes.
Conclusion
CARB’s decision to move the SB 253 Scope 1 and Scope 2 reporting deadline to November 10, 2026 changes the calendar, not the underlying obligation. The $1 billion threshold, the reporting requirement itself, and the 2027 Scope 3 timeline are all intact, and the substance of CARB’s promised clarifying changes remains undisclosed. Sustainability leaders and CFOs should use this window to strengthen data collection processes now rather than treating the extension as time to spare. Executive teams ready to formalize their Scope 1 and 2 measurement approach should begin structured carbon accounting with ASUENE today, so the organization is positioned for compliance regardless of when CARB’s final rule takes effect.
Frequently Asked Questions
Sources
- Sidley Environmental, Health, and Safety Brief. SB 253 Update: CARB Delays Reporting Deadline to November 2026 and Proposes to Clarify Requirements. June 30, 2026. View source
- Proskauer Rose LLP. CARB Defers Initial SB 253 GHG Emissions Reporting Deadline to November 10, 2026. June 2026. View source
- Farella Braun + Martel LLP. CARB To Extend Deadline for SB 253 Reporting in 2026 by Three Months. June 2026. View source
- ESG Dive. CARB Delays Emissions Reporting Deadline by 3 Months. June 26, 2026. View source
- Hogan Lovells. Breaking: CARB Pushes SB 253 Reporting Deadline to November. June 2026. View source
- Fenwick. CARB Proposes Delay to SB 253 GHG Reporting Deadline to Nov. 10, 2026. June 2026. View source
- Linklaters Sustainable Futures. California SB 253: CARB Defers First-Year Reporting Deadline to November 10. June 2026. View source
- Vinson & Elkins LLP. CARB Defers SB 253 Scope 1 & 2 Reporting Deadline by Three Months. June 2026. View source
- Greenberg Traurig LLP. CARB Adopts Initial Climate Disclosure Reporting Regulations to Implement SB 253 and SB 261. March 2026. View source
- Akin. CARB Finalizes Initial Rulemaking Package for SB 253 and SB 261. March 6, 2026. View source
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