California SB 253 reporting support

Section 96076(a) of the regulation requires each reporting entity to report Scope 1 and Scope 2 emissions for its applicable preceding fiscal year on or before November 10, 2026. Scope 3 is not required for 2026. A parent may consolidate the report, and a subsidiary that qualifies as a reporting entity then does not prepare its own.

Which fiscal year counts depends on the year-end. Under section 96076(c), a year that ends on or before February 1 is reported as the year ending in the current calendar year. A year that ends after February 1 is reported as the year ending in the previous calendar year, though the entity may choose its most recent year where that data already exists.

CARB moved the first deadline from August 10 to November 10, 2026 in its bulletin of June 24, 2026.

Section 96072 defines a reporting entity as a corporation, partnership, limited liability company or other business entity with total annual revenues above $1 billion that does business in California. Revenue is the lesser of the two previous fiscal years, measured as gross receipts under Revenue and Taxation Code section 25120(f)(2). It is tested entity by entity, and sales between members of the same combined reporting group are left out.

Doing business in California means doing business and meeting one of two tests from Revenue and Taxation Code section 23101(b): the entity is organized or commercially domiciled in California, or its California sales exceed the indexed sales amount (or 25% of total sales). The Franchise Tax Board lists $757,070 as the 2025 sales amount on a page last updated November 7, 2025. CARB's definition does not use the property and payroll tests.

Five groups sit outside the article under section 96071(b): tax-exempt nonprofits, insurers, government entities and companies majority-owned by them, entities whose only California activity is interstate wholesale electricity, and entities whose only California business is employee pay, including teleworking employees.

Whether a particular entity is covered is a legal determination. Finbryn lays the revenue and sales facts into a worksheet and counsel decides. Section 96074(d) also requires each covered entity to keep California tax records showing it meets the thresholds, for five years.

For the report due November 10, 2026 only, section 96076(b) lets a reporting entity submit one of two things in place of a full report. The first is Scope 1 and Scope 2 emissions for the prior fiscal year that can be determined from information the entity already possessed or was already collecting on or before December 5, 2024. The second is a statement on company letterhead saying the entity is not submitting a report because it held no Scope 1 or Scope 2 information and was not collecting any on or before that date.

The date comes from CARB's Enforcement Notice of December 5, 2024, which promised first-cycle enforcement discretion on the condition that entities make good faith efforts and retain the data for the prior fiscal year. CARB's 2026 Reporting Guidance Document, dated September 1, 2026, adds that it accepts submissions whether or not the data received limited assurance, and that its draft Scope 1 and 2 template, posted October 10, 2025, is voluntary.

Two things follow. A company that was collecting only fuel and electricity data in December 2024 can report what it had, say so, and keep the records. A company that was collecting nothing sends the letterhead statement, which the company issues. Neither route carries over to the 2027 report.

SB 253 directs reporting under the GHG Protocol, and CARB's July 2026 workshop slides repeat that the program is meant to interoperate with IFRS S2 and CSRD. The inventory follows the GHG Protocol Corporate Standard and the Scope 2 Guidance (2015), in this order.

• Boundary. Choose the entities and sites inside the report and the consolidation approach, equity share or control, and write it down. A parent that files for its subsidiaries needs the same boundary as the consolidated filing.
• Scope 1. Fuel burned in boilers, furnaces and company vehicles, plus refrigerant leakage, taken from invoices and service logs.
• Scope 2. Purchased electricity, steam, heat and cooling from utility bills, on the location-based method and, where the company holds contractual instruments, the market-based method too.
• Factors. CARB does not require a specific dataset for 2026. Its guidance notes that EPA had not released eGRID 2024 on its usual timeline, so filers may use eGRID 2023, the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative, or another credible source, and should name it.
• Methodology note. Boundary, factors with edition, GWP values, estimates and exclusions, written so a reviewer can retrace every figure.

The GHG inventory page works through a numbered example with EPA's January 2025 factors.

Fees. CARB sends each reporting entity a written fee notice by December 10 each year starting in 2026, and the fee is due within 60 calendar days of the notice date, with a late fee after that (17 CCR 96074). The regulation gives a formula and no dollar amount that we found, so this page quotes none.

2027 and later. CARB is writing a second regulation. At its July 21, 2026 workshop, staff proposed five required Scope 3 categories from 2027 (purchased goods and services, fuel and energy-related activities, waste generated in operations, business travel and employee commuting) and a limited assurance engagement over Scope 1 and Scope 2 for reports submitted in 2027. Those are staff concepts, not adopted rules. The statute itself starts Scope 3 in 2027 on a schedule CARB sets, and moves Scope 1 and Scope 2 assurance from limited to reasonable in 2030 (Health and Safety Code section 38532(c)).

Penalties. Administrative penalties may not exceed $500,000 per reporting year. From 2027 through 2030, Scope 3 penalties apply only to nonfiling, and Scope 3 misstatements made with a reasonable basis and disclosed in good faith are not penalized.

Finbryn does not decide whether SB 253 covers a company, gives no legal advice and submits nothing to CARB. It provides no assurance. The independent assurance provider you engage does that work. The standards CARB staff floated for 2027 (AA1000AS v3, AICPA AT-C 210, ISAE 3410 with ISAE 3000, ISSA 5000 and ISO 14064-3) all assume a provider that is independent of the company.

What Finbryn can do is hand that provider a file in which every figure points to the invoice, meter read or utility account behind it, so the provider tests from source documents and not from a spreadsheet total. Finbryn also does not sign the letterhead statement, does not advise on SB 261 (see the SB 253 and SB 261 comparison) and does not describe any figure as verified.