California OAL approves climate rules; first emissions due Nov. 10, 2026

The California Office of Administrative Law has approved the state’s corporate climate reporting regulation, ESG Today reported; the first greenhouse gas emissions reports are due Nov. 10, 2026. The approval is the final step in adoption.

SB 253 applies to companies with revenue above $1 billion that do business in California. They must report annually on direct Scope 1 and Scope 2 emissions in the first year of disclosure and add Scope 3 value-chain emissions in subsequent years. SB 261 applies to U.S. companies doing business in the state with revenue above $500 million. They must prepare a report on their climate-related financial risk and the measures they are taking to reduce and adapt to it. Both laws were signed in October 2024, according to ESG Today.

CARB issued a preliminary list last year naming more than 4,000 U.S. companies as likely to be required to comply. Alongside the OAL approval, the agency said it has sent a reminder letter to companies that may fall within the new requirements.

The Ninth Circuit issued an injunction late last year pausing SB 261 pending the outcome of an appeal, while declining a request to halt SB 253, according to ESG Today. That leaves the Nov. 10 deadline tied to the emissions reports while the risk-disclosure half of the regime sits under the injunction.

The November date is itself a postponement. CARB approved the regulation earlier this year and submitted it for final approval with an Aug. 10, 2026 deadline for initial emissions reporting, then announced in June that it had withdrawn the submission to make limited changes. CARB has also confirmed transition measures for the first cycle: companies may use emissions data already collected for the prior fiscal year; Scope 1 and 2 data are not required from companies that had not collected them previously; and filings will be accepted without limited assurance for the 2026 reporting cycle.

This publication described the accommodations in September as an on-ramp for first-year filers and argued in August that an extension is a runway rather than a reprieve. The OAL approval settles whether the rules take effect; the Ninth Circuit appeal over SB 261 and the first round of filings from more than 4,000 potential reporters are what remain open.