Compliance checklist for California's climate disclosure requirements

Quick reference: Key deadlines and requirements

Law	Revenue Threshold	Initial Reporting Timing	Status
SB-253 (Climate Corporate Data Accountability Act)	$1B+ total annual revenue	Scope 1–2 reporting proposed by CARB for August 10, 2026 Scope 3 expected beginning reporting year 2027	Rulemaking in progress
SB-261 (Climate-Related Financial Risk Act)	$500M+ annual revenue	Timeline pending litigation outcome and CARB guidance	Enforcement stayed

Phase 1: Initial assessment and eligibility ✓

Determine your reporting entity status

[ ] Calculate total annual revenue for your business entity

[ ] Confirm if you're a U.S. company doing business in California

[ ] Identify if you're in scope for SB-253 ($1B+ revenue) or SB-261 ($500M+ revenue)

[ ] Document parent company and subsidiary relationships that may affect reporting

[ ] Review California's climate disclosure laws applicability to your organization

[ ] Consult California Air Resources Board (CARB) FAQs for clarification on edge cases

Understand your reporting requirements

[ ] For SB-253: Prepare for Scope 1 and Scope 2 greenhouse gas emissions reporting

[ ] For SB-261: Assess climate-related financial risk exposure and align internal frameworks with TCFD in preparation for future enforcement

[ ] Review Task Force on Climate-Related Financial Disclosures (TCFD) requirements

[ ] Understand IFRS S2 alignment for climate disclosures

[ ] Identify your fiscal year reporting period

Phase 2: Governance and organizational setup ✓

Establish governance structure

[ ] Assign executive-level ownership for California's climate laws compliance

[ ] Create cross-functional compliance team (sustainability, finance, legal, operations)

[ ] Define roles and responsibilities for emissions data collection and climate risk assessment

[ ] Establish management oversight processes for climate disclosure quality

[ ] Document decision-making authority and escalation procedures

[ ] Set up regular stakeholder communication processes

Build internal capabilities

[ ] Assess current ESG reporting capabilities and identify gaps

[ ] Train team members on GHG emissions calculation methodologies

[ ] Develop understanding of climate scenarios and scenario analysis techniques

[ ] Create project management framework with clear milestones

[ ] Establish budget and resource allocation for compliance activities

💡 See the full company primer for California SB-253 and SB-261.

Phase 3: Data systems and collection infrastructure ✓

Note: SB-261 enforcement is currently stayed. The steps below are recommended for readiness and voluntary alignment during the interim period.

Scope 1 emissions data collection (SB-253)

[ ] Inventory all direct greenhouse gas emissions sources (fuel combustion, industrial processes, fugitive emissions)

[ ] Establish data collection procedures for facility-level emissions

[ ] Implement tracking systems for fuel consumption, energy usage, and process emissions

[ ] Document calculation methodologies and emission factors used

[ ] Create quality control procedures for emissions data validation

Supply chain and Scope 3 preparation

[ ] Map key supply chain partners and their emissions reporting capabilities

[ ] Develop supplier engagement strategy for future Scope 3 requirements

[ ] Begin collecting baseline supply chain emissions data as a starting point

[ ] Establish partnerships with key vendors for emissions data sharing

[ ] Create supplier questionnaires and data collection templates

Climate risk data systems (SB-261)

[ ] Develop climate scenarios relevant to your business operations

[ ] Create risk assessment frameworks for physical and transition risks

[ ] Establish data collection processes for climate-related financial impacts

[ ] Implement risk management tracking and monitoring systems

[ ] Document methodologies for climate risk quantification

Phase 4: Reporting framework development ✓

SB-253 Emissions reporting framework

[ ] Select appropriate greenhouse gas emissions calculation methodologies

[ ] Align reporting framework with GHG Protocol standards

[ ] Develop templates for annual emissions reporting

[ ] Create processes for data verification and quality assurance

[ ] Establish limited assurance readiness (required 2026)

[ ] Prepare for reasonable assurance transition (required 2030)

SB-261 Climate risk reporting framework

[ ] Adopt TCFD reporting structure (Governance, Strategy, Risk Management, Metrics & Targets)

[ ] Develop climate scenario analysis capabilities

[ ] Create financial planning integration for climate risks

[ ] Establish metrics and targets for climate risk management

[ ] Document risk management processes and controls

[ ] Develop repeatable climate-risk reporting processes that can be activated once SB-261 enforcement resumes

Phase 5: Third-party assurance preparation ✓

Assurance provider selection & engagement

[ ] Research qualified third-party assurance providers

[ ] Issue RFPs and evaluate assurance provider capabilities

[ ] Select assurance providers for SB-253 emissions reporting and assess future assurance needs for SB-261, subject to enforcement and final CARB guidance

[ ] Negotiate assurance engagement terms and timelines

[ ] Establish working relationships with assurance teams

Assurance readiness

[ ] Document all emissions data sources and calculation methodologies

[ ] Create audit trails for climate risk assessments and financial impact analyses

[ ] Establish internal controls for data collection and reporting processes

[ ] Prepare management representations and supporting documentation

[ ] Conduct internal readiness assessments before formal assurance engagement

💡 See a full breakdown of the penalties and compliance for California’s climate bills.

Phase 6: Regulatory compliance and submission ✓

Stay current with CARB requirements

[ ] Monitor California Air Resources Board rulemaking updates

[ ] Review CARB’s SB-261 voluntary submission docket (opened December 1, 2025) and determine whether early participation is appropriate

[ ] Review updated FAQs and guidance documents regularly

[ ] Participate in relevant webinars and stakeholder engagement sessions

[ ] Track any changes to disclosure laws or implementation requirements

Submission preparation

[ ] Complete first report preparation well before reporting deadlines

[ ] Conduct internal review and approval processes

[ ] Obtain required third-party assurance attestations

[ ] Prepare final submissions in required formats

[ ] Plan for public disclosure and stakeholder communication

Phase 7: Ongoing compliance and improvement ✓

Continuous improvement

[ ] Establish annual review processes for data quality and completeness

[ ] Monitor best practices and emerging methodologies in climate disclosure

[ ] Benchmark against peer companies and industry standards

[ ] Integrate climate disclosure with broader sustainability reporting

[ ] Continuously engage supply chain partners for improved data collection

Long-term strategic integration

[ ] Align climate disclosures with corporate sustainability strategy

[ ] Integrate climate risk management into business planning processes

[ ] Use emissions data and climate risk insights to inform business decisions

[ ] Communicate progress and improvements to stakeholders regularly

[ ] Prepare for potential expansion of disclosure requirements

Key takeaways to achieve CA SB-253 and SB-261 compliance:

Start early: Begin preparation immediately - these are complex, multi-month projects
Good-faith efforts: CARB will show leniency for 2026 if demonstrating good-faith compliance efforts
Cross-functional collaboration: Success requires coordination across multiple departments
Quality data systems: Invest in robust data collection and management infrastructure
Professional support: Consider engaging specialized consultants for complex technical areas

Preparation timeline:

Illustrative preparation timeline below is SB-253 focused. Actual timelines will vary based on organizational complexity and final CARB regulations.

First 30 days

[ ] Complete eligibility assessment

[ ] Assemble core compliance team

[ ] Engage third-party assurance providers

[ ] Begin emissions data inventory

Next 60 days

[ ] Complete governance structure setup

[ ] Finalize data collection systems

[ ] Begin supplier engagement

[ ] Start climate risk assessment

Next 90-180 days

[ ] Complete baseline Scope 1–2 emissions inventory

[ ] Strengthen data controls and documentation

[ ] Pilot supplier engagement for Scope 3

[ ] Advance climate-risk assessment readiness (SB-261)

Helpful resources:

Tick off your compliance checklist with Pulsora

Checking every box on a compliance checklist for California Senate Bill 253 and Senate Bill 261 requires more than good intentions — it demands reliable data systems, seamless supplier engagement, rigorous risk assessments, and audit-ready assurance.

Pulsora is built to help you get there. Our platform centralizes emissions data collection, streamlines Scope 3 supplier requests, aligns financial risk disclosures with leading frameworks, and integrates third-party assurance to ensure accuracy and credibility.

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Regulatory status reflects publicly available guidance as of December 29, 2025. California climate disclosure requirements remain subject to ongoing rulemaking and litigation.