California climate disclosure: check the revenue tests, then build the emissions and risk evidence
Check each revenue test, then give every emissions and risk figure an owner and a data trail an assurance provider can follow.
In Short
- SB 253: over $1bn revenue.
- SB 261: over $500m, biennial.
- Check CARB rules and court status.
California has two climate disclosure laws for large companies doing business in the state. This guide summarises the statutory text of Health and Safety Code section 38532 (the Climate Corporate Data Accountability Act, SB 253) and section 38533 (SB 261) as published on the California Legislative Information site. CARB regulations, enforcement notices and any court rulings were not reviewed, and they may affect dates and duties, so check current status before relying on any date here. It is orientation, not legal advice. Sources checked 5 Oct 2026.
Two laws, two revenue tests
Section 38532 applies to a reporting entity: a partnership, corporation, limited liability company or other business entity formed under US state or federal law, with total annual revenues over $1 billion, that does business in California. Section 38533 applies to a covered entity with revenues over $500 million that does business in California, excluding businesses regulated by the California Department of Insurance or in the business of insurance in another state.
Which law could apply? (invented companies)
- Over $1bn (38532) and over $500m (38533).
- Check 'doing business' with counsel.
More on two laws, two revenue tests
Both tests use the prior fiscal year's revenue. Neither is limited to listed companies.
SB 253: scope 1, 2 and 3 emissions
Section 38532 required CARB to adopt regulations on or before 1 July 2025. Under the statute, reporting entities disclose scope 1 and scope 2 emissions starting in 2026, on or by a date CARB sets, and scope 3 emissions starting in 2027 on a CARB schedule, in each case for the prior fiscal year.
More on sB 253: scope 1, 2 and 3 emissions
Emissions are measured following the Greenhouse Gas Protocol standards and guidance. Reports may be consolidated at the parent company level, and a qualifying subsidiary then does not need a separate report.
Assurance
The statute requires an assurance engagement by an independent third-party provider. For scope 1 and scope 2 emissions, assurance is at a limited level beginning in 2026 and a reasonable level beginning in 2030.
Statutory milestones (check CARB rules and court status)
- 1 Jul 2025CARB regulations due (38532)
- 1 Jan 2026First SB 261 report due; biennial after
- 2026Scope 1 and 2 disclosure; limited assurance
- 2027Scope 3 disclosure on CARB schedule
- 2030Scope 1 and 2 reasonable assurance
More on assurance
During 2026 CARB reviews scope 3 assurance trends and may establish a scope 3 assurance requirement on or before 1 January 2027. The section also provides for administrative penalties set through CARB regulations. Choose your assurance provider early, because they will test the data trail behind every number.
Operational Data Behind the Numbers
Scope 1 and 2 figures depend on fuel, refrigerant and purchased energy records by site; scope 3 depends on purchased goods, transport and product data. Manufacturing and inventory systems already hold some of that activity data, such as quantities received from suppliers and shipped to customers.
Worked Example: Data Owners at Plant PL-7
| Data | Scope | Owner |
|---|---|---|
| Natural gas and diesel use | Scope 1 | Facilities |
| Purchased electricity | Scope 2 | Facilities and finance |
| Purchased materials by supplier | Scope 3 | Purchasing |
| Outbound shipments | Scope 3 | Logistics |
- Natural gas and diesel use
- Scope
- Scope 1
- Owner
- Facilities
- Purchased electricity
- Scope
- Scope 2
- Owner
- Facilities and finance
- Purchased materials by supplier
- Scope
- Scope 3
- Owner
- Purchasing
- Outbound shipments
- Scope
- Scope 3
- Owner
- Logistics
More on operational Data Behind the Numbers
Decide who owns each data source, how estimates are documented and how corrections are recorded. Your finance and sustainability teams, with the assurance provider, decide what is reported.
Questions
Does SB 253 apply to private companies?
The statutory definition covers partnerships, corporations, LLCs and other business entities with over $1 billion revenue doing business in California. It is not limited to public companies.
Do subsidiaries need separate reports?
Under both sections, reports may be consolidated at the parent company level, and a subsidiary that qualifies on its own is then not required to prepare a separate report.
Which standard does SB 253 use for emissions?
Section 38532 requires measurement in conformance with the Greenhouse Gas Protocol standards and guidance, including the corporate and value chain (scope 3) standards.
Does V5 calculate emissions or file reports?
No. V5 is not an emissions accounting tool. Production, inventory and supplier records it holds can support your team's data requests; your people decide what is reported.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
FTC Made in USA Labels (16 CFR 323) and Endorsement Disclosures
USDA Bioengineered Food Disclosure (7 CFR 66): Labels and Records
California Prop 65 Warnings: Labels, Short Form, Online Sales and Supplier Notices
US DSCSA Enhanced Drug Distribution Security Readiness
TSCA PFAS Reporting (40 CFR 705): Scope, Articles and the 2027 Window
US Medical Device Readiness Under the QMSR: Clearance, Quality System and Postmarket