California Climate Disclosure Laws (SB 253 and SB 261)SB 253 / SB 261
SB 253 and SB 261 are California climate disclosure laws with live deadlines. SB 253's first filing was deferred from 10 August 2026 to 10 November 2026. CARB has stated it will not enforce SB 261's 1 January 2026 deadline while a Ninth Circuit injunction is on appeal.
- SB 253 threshold
- > $1bn revenue
- Doing business in California
- SB 261 threshold
- > $500m revenue
- First SB 253 deadline
- 10 November 2026
- Deferred from 10 August 2026
- SB 253 Scope 3
- From 2027
- With assurance
- SB 253 penalty
- Up to $500,000 / year
- SB 261 penalty
- Up to $50,000 / year
- Regulator
- CARB
Where these figures come from
The live enforcement position, which differs from the statutory dates
The first SB 253 filing was deferred from 10 August 2026 to 10 November 2026. CARB has stated it will not enforce SB 261's 1 January 2026 deadline because of a Ninth Circuit injunction, and will set an alternative date once the appeal resolves. For the first SB 253 cycle, CARB will not impose penalties for incomplete reporting where a company can show a good-faith effort.
SB 253 requires companies with over $1 billion in annual revenue doing business in California to report Scope 1 and 2 greenhouse gas emissions, with Scope 3 following in 2027. SB 261 requires companies above $500 million in revenue to publish climate-related financial risk reports. Penalties reach $500,000 per year for SB 253 and $50,000 per year for SB 261. The first SB 253 deadline was deferred to 10 November 2026. CARB has stated it will not enforce SB 261's 1 January 2026 deadline while a Ninth Circuit injunction is on appeal.
SB 261 injunction and CARB enforcement position
SB 261 is subject to a Ninth Circuit injunction. CARB has stated it will not enforce the 1 January 2026 deadline while the appeal proceeds, and will set an alternative reporting date once the appeal resolves. The statutory obligation remains; only the enforcement date has changed.
First-cycle good-faith relief for SB 253
CARB's first-cycle relief covers incomplete reporting where a company demonstrates a good-faith effort. It does not exempt a company from reporting. The relief applies only to the first SB 253 cycle.
Penalties
Statutory annual maximums, with first-cycle enforcement discretion applied by CARB.
SB 253 — up to $500,000 per year
Statutory maximum for violations of the greenhouse gas reporting requirements.
SB 261 — up to $50,000 per year
Statutory maximum for violations of the climate-related financial risk reporting requirements.
First-cycle good-faith relief (SB 253)
For the first reporting cycle, CARB will not impose penalties for incomplete reporting where the entity demonstrates a good-faith effort to comply.
Does this apply to you?
Revenue thresholds plus doing business in California. Headquarters outside California, including outside the United States, is not an exemption.
- SB 253: annual revenue above $1 billion and doing business in California
- SB 261: annual revenue above $500 million and doing business in California
- Both are entity-level tests on total revenue, not California revenue
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Common questions
- When is the first California SB 253 report due?
- 10 November 2026, deferred from the original 10 August 2026 date. It covers Scope 1 and Scope 2 emissions; Scope 3 reporting and assurance are anticipated from 2027.
- Is SB 261 still in force?
- The law stands, but CARB has said it will not enforce the 1 January 2026 deadline while a Ninth Circuit injunction is under appeal, and will provide an alternative reporting date once that resolves.
- Do these laws apply to companies outside the United States?
- Yes, if they meet the revenue threshold and do business in California. The tests are on total entity revenue, not revenue earned in California.