TL;DR
SB 261 compliance is presently voluntary, but the first element of SB 253 compliance is due August 10, 2026, so fill out the CARB template with your Scope 1 and Scope 2 emission numbers. If you need a consultant’s advice, Climate Positive Consulting is well suited to the task. Also feel free to check back with Climate Positive Consulting for the CARB upload link, which has not yet been released by the agency.
FULL UPDATE:
2026 is a milestone year for catalyzing corporate climate action with the roll out of two disclosure laws impacting high revenue companies operating in California. If your large company has a presence in California, compliance with the state’s corporate climate disclosure laws, SB 253 (requiring carbon footprint disclosure) and SB 261 (requiring climate change financial risk disclosure) should be on your radar.
Interestingly, while enforcement of SB 261 (requiring climate change financial risk disclosure for companies with annual revenue over $500 million) has been postponed with legal holdups, 150 companies went ahead and disclosed their financial risk, uploading their compliance reports to the State website voluntarily! They likely took voluntary action due to the persistent, widespread, underlying market pressure from investors, customers–and the genuine wisdom in taking steps to prepare for a more volatile climate that can harm supply chains, labor, and facilities and their bottom line.
Meanwhile, on the SB 253 carbon footprint front, thus far no legal tactics have slowed the planned implementation; billion dollar companies must calculate and report their Scope 1 (emissions from fuel) and Scope 2 (emissions from electricity generation) by August 10 of 2026. While the State has yet to provide a link to upload SB 253 reports, it has provided a template spreadsheet , and it is reasonable to expect an online portal link to upload completed templates by early August 2026. Check back with Climate Positive Consulting for the CARB upload link, which the agency has yet to publicly release.