Simplifying SB 253 & SB 261 Compliance

Introduction and agenda

Hi everyone. Thanks for your patience as we're getting started and allowing for a few minutes for folks to join. We're really looking forward to this conversation today, and I'm super excited to be joined by Mel Blackmore as well. I'm going to get a little bit into the agenda, and then I'll introduce myself and Pulsora, and then Mel will also introduce herself and Carbonology. Just as a reminder, for this conversation, please feel free to add questions in the chat and we will definitely make sure to spend some time on Q&A as well.

For the next 45 minutes, we have quite a bit of content to cover. This is a very exciting topic. Things have been changing by the week, by the day, and so we want to make sure we get to everything so that we can give you a comprehensive overview for these bills. We're going to start with introductions, then we will speak about the climate reporting landscape, and then we will talk about the specifics of these two bills. We'll speak on framework interoperability, so what it means for you who may be reporting against other frameworks and standards, what does that mean when you think about compliance with these two bills? We'll talk a little bit about what that roadmap actually looks like, and then finally, we will get to some practical advice and a demo of what it might look like on a platform like Pulsora, and working with an assurance firm like Carbonology. And then we'll definitely make some time for Q&A at the end.

About Pulsora and Carbonology

Just to introduce myself and Pulsora before we kick off this content: my name is Jessica Mathis, and I am a product manager at Pulsora. I lead our carbon product, and I've been working in the sustainability technology and AI space for the last eight years. So really excited to be with you today.

And then, as I mentioned, we're very fortunate to be joined by Mel Blackmore, founder and CEO of Blackmores UK and Carbonology, who also has extensive experience in this space.

Hi. Thank you very much, Jessica, and welcome everybody to today's webinar. I'm Mel Blackmore, founder and CEO of Carbonology. Carbonology is an accredited verification body that verifies organizations' emissions against international standards like the GHG Protocol and ISO 14064, which is a requirement for various global mandatory reporting disclosures, which is the topic of discussion for today. My background is about 20 years in sustainability standards, from ISO 14001 to a full range of different international standards. Happy to answer any questions about that later on in the webinar.

The climate reporting landscape

I can provide a bit of context in terms of the regulatory landscape for greenhouse gas emissions verification reporting. Before we look at the regulatory requirements, which are all the green dots along the left-hand side, there is a lot of pressure that's coming, not only externally but internally. We've seen a progression of seniority in terms of responsibility and accountability when it comes to demonstrating an organization's environmental footprint and their level of commitment to achieving net zero. We're now seeing that within the C-suite, quite often there is a CSO, a chief sustainability officer, and so we're finding that there's requests coming in for verification from them in order to be able to demonstrate to the leadership team and other key stakeholders exactly where they're at in terms of their journey in relation to net zero.

Many organizations are also verifying their carbon footprint to meet other ESG rating providers' requirements, such as CDP or EcoVadis. But where we've seen a huge increase in legislation and regulations is across ESG, both from an international context, obviously the topic we'll be covering today, right through to a more local level, whether that be here in the UK, European, then UK, and also sector-specific requirements for verification. So it's coming from all angles now, but the benefit of verification is that once you've calculated your emissions and reported your emissions and had them verified, you only need to do that once, because then that enables you to comply with all of these different requirements.

California SB 253: the emissions reporting bill

That lays a great foundation to get into what the requirements associated with these two bills are. There are two bills that are primarily discussed as the California climate bills: SB 253 and SB 261. I'm going to talk a bit about both of them, and also some of the latest updates.

Just for folks to know, these bills have not had their final version codified through the legislature. They've had some changes, some working sessions and workshops this year to formally finalize certain fee structures and other eligibility criteria. But the main bulk of the content is pending external litigation being quite formalized and finalized. So we want to spend the bulk of the time here today and emphasize that it's important to stay abreast of these things as they may have a little bit of change, as we've seen with some of the other topics like the SEC bill and CSRD in Europe.

The first one is SB 253. SB 253 is what we think of as the emissions reporting bill. This is very focused on reporting Scope 1, 2, and 3 emissions. In the first year, it's just focused on Scope 1 and 2. This has a revenue threshold, so it's focused on companies which are a bit larger, doing at least $1 billion in annual revenue, and they're also considered doing business in California. Doing business in California is a very specific legal definition, which essentially means that they have either a high volume of sales in California, which is around a $750K threshold, or it is having some sort of business residency or occupancy set up in California. So if you're curious whether this applies to you and your only association with California is remote workers, then this would not necessarily apply to you. Similarly, non-profits are also exempt from both of these bills.

For 253 specifically, the guts of it is reporting on your Scope 1 and 2 emissions, and there is a due date that was announced, pushed back by six weeks in the last week. So now it is August 10th, 2026. In the first year, it's just looking at Scope 1 and 2, and then subsequent years, Scope 3 is going to be part of it as well. Assurance plays a big part in this bill as well, so that is why we really want to have this conversation today and talk about what it means if this is going to be one of those things that's pushing your business to either start accounting for your emissions, or maybe you've been doing some emissions quantification but haven't pursued a formal assurance program yet. This is a great time to get started with that.

California SB 261: the climate risk bill

The second bill is SB 261. This is what I would think of as the climate risk bill, and this is something that, as of last week, is actually on pause. This is going to be reviewed in the January timeframe. The current expectation or requirement was that folks would publish an external-facing climate risk report to their website on January 1st, and then they have six months to share that link to that external website with CARB, the California Air Resources Board, who is regulating these. That is now on pause, so most likely will be delayed until some later time in 2026.

This one has a slightly smaller threshold with regards to revenue, so this is only looking at $500 million. A greater number of companies are going to be subject to 261 compared to 253. But they both have the same "doing business in California" legal definition that they need to follow.

Framework interoperability

One other thing that is really important to emphasize with these two bills, and ties into what Mel was just talking about, is they're both very aligned to existing frameworks and standards. California is not coming up with their own framework or standard for how to quantify and report these things. It's all pre-aligned with existing ones.

For 253, the measures that are reported need to be aligned with the GHG Protocol, which is the internationally recognized main standard for quantifying your corporate GHG emissions, and many other regulations are aligned with that. For 261, it's looking at any climate-risk-aligned reporting framework. So what that means is typically companies are thinking about TCFD or ISSB S2. If you're already publishing a report that aligns to either or both of those, then that is great to also submit to CARB, and you don't need to change your process at all. Just need to submit that external link in the first six months of next year.

As Mel mentioned, the great thing about these is once you're assuring the data for one particular report, you can leverage that pre-assured data for any of these reports. If you're already going through an assurance and review process or governance process around your TCFD report, then that is ready to go for your 261 compliance. Similarly, if you're already pursuing GHG external assurance with a firm like Carbonology, then you can leverage that assurance for any of your GHG reporting, including this California Bill 253.

Something that is really important to think about, especially from a platform perspective, like how can technology help and support this process, is really making sure to unify and standardize those data points that are going to be assured. Then be able to map those across these many different frameworks and standards, including the California ones, to make sure that you can get the most value out of that data that you're spending a lot of time and effort making sure is comprehensive, high quality, compliant, auditable, and assured.

Global reporting jurisdictions

I'm going to cover this from the point of view of a global reporting perspective. Obviously, I know that the main topic of conversation are the SB regulations, but I think it's important for organizations that are global, that have services and products that they're offering internationally, that they're also aware of the disclosure requirements internationally. Also, what is the eligibility criteria for that, and what are the verification requirements?

As it stands at the moment, there are some changes Jessica mentioned just last week that we're just catching up on. But I just wanted to give you an idea around the jurisdiction in terms of the main global reporting requirements.

We've got the EU CSRD. There is also the CSDDD, which is all about due diligence, and there is also an EU Green Claims Directive, which very much focuses on verification. For the first time, if an organization is in breach of that EU directive, they could potentially be banned from marketing their products and services. So that's the first time we've seen that in the legislative requirements associated with environmental requirements.

Then we've got the US SEC climate rules and the ISSB. As you can see, there is a slight variance in terms of what must be disclosed, where, and when. They have got slightly different time frames, and there is some leniency when it comes to the reporting of Scopes 1, 2, and 3 emissions. Typically, the main requirements are Scopes 1 and 2, and Scope 3 is coming down the line as well, along with the level of assurance.

Reporting criteria comparison

In terms of the reporting criteria across the three main ones, for Scope 3 disclosures, it's mandatory for the EU CSRD and the California regs, but it's voluntary for the US SEC.

For the materiality test, only double materiality is required for the EU, financial materiality for the US, but there is no materiality test required for the California regs.

We're seeing the reporting already coming into place in the EU, even though there was something called the Omnibus which paused some of the regulations. That's still coming down the line.

Assurance requirements

In terms of assurance requirements, there are two levels of assurance. We've got limited level of assurance, which is a smaller sample of data and doesn't give full assurance on the greenhouse gas emissions, which is typically a requirement of the banks for getting access to sustainable-linked loans or green bonds. That's typically what a lot of the FTSE 100 have got, and the S&P 500. However, those organizations that would like to demonstrate greater confidence in their greenhouse gas emissions assurance are going for reasonable levels of assurance. Reasonable level of assurance is where there is a greater sample and a greater level of confidence in the assurance of the emissions.

For the EU CSRD, it's mandatory for limited at the moment, but that's moving over to reasonable. The US SEC, there isn't any. For the California regs, that's going to be phased from limited to reasonable as well.

In terms of the Scopes reassurance timeline, for the EU it's limited from year one. US it's none, and for California that's limited by 2030. In terms of safe harbor and liability, the EU CSRD has got assurance-based accountability, but in the US and California, we've got safe harbor, but that's going in a phased approach for California.

Verification requirements

Verification is required for the top three frameworks. The GHG Protocol is the most widely adopted standard alongside ISO 14064 part one. There are other standards, and there are actually about 20 or so different reporting standards, but there are four main ones. The most popular two globally are the GHG Protocol and ISO 14064. There's a phased approach for verification, from limited to reasonable in many cases.

Compliance checklist: data foundation

First, I want to walk through what a checklist might look like to get ready for California compliance. This is assuming that you are not perhaps doing a formal process for some of these other regulations, which I'm sure some of you already are.

The first thing that's important to do for compliance and getting ready for that audit-ready data is to establish a data foundation. This means taking your relevant Scope 1 and 2, especially for that first year, data from wherever it may live today, which could be in folks' emails, a mailed utility bill, or it might exist on an energy management system or a procurement system. Really bringing all of that data together into a good central place to work with. In addition, really validating and standardizing that data and those metrics to ensure that you have high-quality data being brought in.

Compliance checklist: calculate emissions

The second item is to calculate emissions. Based on that data foundation, you want to make sure we're calculating emissions GHG Protocol aligned, so for Scopes 1, 2, and 3. Something that is really important for this, that Pulsora enables, is providing a comprehensive emission factor library out of the box, ready for you to use, so that you can have the most relevant emission factor matched to your activity data as possible. You want to use an emission factor that is representing your data in terms of when an activity has happened and where it has happened, and maybe even what industry it has happened in, as closely and accurately as possible. That's going to ensure that those outputs of your emissions calculations are as accurate as possible.

The reality is, you aren't always going to have all the primary data that you need. A piece of calculating emissions is going to be gap-filling, creating some estimations. You can use a platform like Pulsora to have really comprehensive and complex estimations, or you can have a really streamlined estimation process that's a little bit more standardized and generalized. Either is fine. The most important thing with these first two steps is to make sure that you have a strong foundation, strong data governance, and that you're documenting your processes and your approach to all of these things.

Compliance checklist: climate risk reporting

Once you have that foundation, that baseline for your emissions, now we can use that data to inform your key climate risks. Getting started with your key climate risks, the first thing, if you aren't already reporting risk against TCFD or IFRS S2 framework, is to choose one. I think TCFD is a great one to start with. It's pretty streamlined and simplified. There are about 11 metrics involved. It's a really great place to get started if this is your first time doing a climate risk report.

The other big important thing about climate risk is this brings in a lot of need for processes around governance, conversations, and aligning across various different entities and stakeholders in your companies to really make sure that those risks are aligned and agreed upon across many different groups. Climate risk reporting is a little bit less prescriptive than emissions calculation, but very important. The process by which you formalize those risks and talk about those risks is really a big piece of it.

Compliance checklist: verification and reporting

Once you have some of those risks identified and those gaps and mitigation levers, you have your emissions baseline, that is when you're going to transition into that verification and assurance process. With a platform like Pulsora, you can have data controls, validations, and you can go into an audit with confidence. This data and transparency to everything that has happened to the data along the way is really a key piece. With the assurance, as we've been speaking to, you can assure that data once and then use it across many frameworks. This is a very valuable process that scales.

From a California perspective, we have that reporting step. Both of these bills have an annual reporting component. The 253, as mentioned, is going to be sort of towards the end of the summer in the first year of Scope 1 and 2 data. There's quite a bit of flexibility for how you report your Scope 1 and 2 data. I highly recommend checking out the links in CARB's website FAQ for how to format this data and some of the suggested data points they recommend. As long as it's GHG Protocol aligned, you should be good to go.

Finally, providing a public link to your climate risk report in the summer as well. So publishing it in January and sharing it with CARB six months later is the other key aspect for 261. I know we mentioned it's on pause, but it doesn't necessarily mean that you need to stop all efforts because, in all likelihood, it's probably going to continue on sometime later next year. Maybe not January 1st, maybe delayed by a bit, but I think it's still something that's quite important, and a great time to get your ducks in a row.

Pulsora platform demo

I want to share a quick demo of how a process like this might work in a platform like Pulsora. Here we are in the Pulsora platform, and what I want to talk about today is the journey from an individual utility bill all the way through to calculating emissions, aggregating with other activity data, and then rolling that up into a report.

The first thing we're going to do is go to a task. This task is something that you can send to a facility manager or someone who may be collecting and may have access to those utility bills. Since we're talking about Scope 2, a great example of that is electricity consumption. Let's say I am a facility manager and I have an electricity bill available, but I don't want to type all this data in. Something that I can do using Pulsora is upload the invoice directly, and then it can be scanned using AI for those values. So I don't even have to fill it out myself. This is really valuable from a preventing-fat-fingering perspective, but also making sure that evidence file is tied to your activity, your electricity consumption. That's going to help you down the line from an auditability perspective. When folks are assuring your data, they can not only look at the values, but they can also confirm in the actual attached evidence that these values are indeed correct.

You can see in this example that we're able to pull those values from this utility bill and have these values come directly from this PDF and even check against it. For example, you can see this dollar amount was picked up for the spend. We also have electricity consumption data later on in this quite long bill, in kilowatt-hours.

Pulsora demo: Scope 2 calculator

In Pulsora, we have dedicated workspaces for each of the scopes and categories associated with the GHG Protocol so you can focus on an individual piece at a time. Here is our Scope 2 calculator. At the top is summary data about my location and market-based emissions. We have time data, so what period these emissions represent. We're focused on calculating our 2025 emissions for submission in 2026. We also have organization data, so what part of this business am I looking at. On Pulsora, you can also include upstream and downstream partners, customers, and suppliers across your value chain to collect and manage data across them. But in this instance, we're focused on our corporate data.

In the middle, we have our activities. This is all the details I am collecting, maybe through tasks like that facility manager task we just looked at, or through a bulk upload, an API integration, or many other ways we can get that data ingested and available onto the platform. For an individual record, we also have a detailed view of all the data associated with it. This includes the emission factor details, which specific emissions factors were provided, the GWP, and many other details that can be valuable in helping reconstruct the sample data an auditor may want to look at and understand where it came from.

Finally, we have an Evidence and Audit Log. Evidence is where you would see that attached file. Audit log is where you would see any time any user has added, edited, or modified the data in any way for this transaction. We always have traceability.

Pulsora demo: gap-filling and estimations

Now we've collected a lot of different primary data and collated it. But maybe there's still some data gaps. The next step is to use this Calendarize Data screen to help fill gaps. We've done a little bit of this work ahead of time, so you can see blue squares which represent estimated data, and white which represent actuals. This is a really helpful visual to understand where my estimates and gaps lie and where my actual data is coming from, and to compare and contrast different facilities over time and look for trends. We also have the ability to handle things like if a facility didn't open until July, then it would be closed and no data is represented earlier and no estimations are generated. If I want to generate new estimations or refresh some of the data, maybe I have new primary data that's been added, I can use these to go through that workflow.

Pulsora demo: Catalogs and reporting

Now I have generated my data, I've filled my gaps, but I also need to report, and especially figure out how I want to report against my TCFD data points. I'm going to navigate over to Catalogs. Catalogs is a repository of various different metrics and values that I want to use for reporting. This is kind of my master data management of all my sustainability details. For this particular catalog, I have all the different TCFD metrics grouped by topics.

I want to take a look at an example and see how we can use Pulsora to help get started with filling out a metric, especially if this is my first time. I'm going to clear this so we can start from scratch. Essentially, this is the metric. We're looking at climate-related risks and opportunities. We have the instructions directly brought in from the TCFD framework. As a first step toward filling this out, if I'm someone who is not as familiar, this is my first time, and I'm not as comfortable starting with a blank sheet of paper as opposed to editing from a draft, I can use Write with Pulsora AI to generate that first draft of the metric to help propel me to get started.

Here's the draft response. You can see there's a specific framework that's been provided, which is super helpful for me to think about climate-related risks and opportunities and the impact, and how I may want to talk about them. The other thing is that it's prompting me with these fill-in-the-blanks, almost like a Mad Libs of sorts, to make this custom, make this my own, and remind me that this is not the final version. This is really using AI to help get me started with that metric specifically.

Once I have this metric, once I have all of that data, plus the GHG data we had calculated and aggregated and brought into these metrics, the final step is really to report. I can use the Reports module in Pulsora, which maps various frameworks and standards against my same set of metrics in my catalog. This is the one-to-many we've been talking about: share your data once and then use those metrics across many different frameworks and reports.

In this case, we want to generate a climate risk report, so I'm going to click into this. I can choose which period of the report I want to generate, which part of my organization, and then I can export this report. When I want to view this report, it's going to have a full published history. For example, I can see and download any previous version of this report that I've ever created. I have full traceability and a snapshot to that. Now I'll open it up to show you this sample report. This is a TCFD report, a Word report, although we can export in other formats as well. I can see specific templated aspects of the report as well as the responses, which are coming directly from those metrics I had just used AI to draft and then had a conversation with external teammates and confirmed. Now this is all collated in my report and it's ready to be sent to a PR communications and marketing team to really beautify and finalize for publication on my public website. Then I can use that link to submit to CARB for my 261 compliance.

Self-reporting versus independent verification

Organizations are either going to be self-reporting and marking their own homework, which is the majority of organizations at the moment, versus independent verification. Let me explain the difference.

With self-reporting, unfortunately there is potential for bias, whether done intentionally or unintentionally. There is a possibility of under-reporting emissions to help potentially avoid penalties or negative publicity. In the vast majority of cases this doesn't happen, but it could happen because nobody else is checking it.

There is also a lack of transparency in the data being calculated, including the methodology. There may also be a situation where an organization is making it up as they're going along. They're not actually using an international framework of best practice like the Greenhouse Gas Protocol or ISO 14064. So they might be missing key points when it comes to identifying their scope and boundaries, quantification methodology, and reporting.

That can lead to inconsistencies. If they haven't got that framework, that benchmark, there could be significant differences in reporting year on year. Especially if there are different people coming into the organization involved in the calculations, if they haven't got that framework to report against and have it independently checked, that doesn't actually give you any type of guarantee that the data is accurate. The knock-on effect: not only could you be liable for false claims, but you could be in breach of mandatory reporting disclosure requirements.

The independent verification route

What does independent verification mean? There are some core principles within ISO 14064: accuracy, reliability, transparency. This brings a higher level of assurance that reported emissions data is accurate and complete. You have to be very upfront and honest about the methodology used. The fact that there is an independent accredited third party coming in to validate your claims brings added credibility and confidence to key stakeholders, especially investors. Investors would have typically been looking at at least three years' worth of audited financial reports, and now they're looking at several years of carbon accounting reports that have been independently checked as well. So they're treating it the same as financial reporting. That's how serious it's been taken in ESG data.

It helps to identify inaccuracies of data. This could be a result of not using the correct conversion factor for a particular country, or in some cases, some countries will have state or region-specific factors. If you're dealing with the calculation of several countries, this could easily be calculated incorrectly. At the end of the day, we're only human as well, so the input of the data can be incorrect. In some cases, we don't actually find that there's a GHG report at all. One of the main challenges is the spreadsheet monsters we sometimes come across, which is why it's an absolute joy and pleasure to audit clients that are using Pulsora software. I'm slightly biased there, but it is true. It makes life so much easier from an audit perspective having everything at your fingertips, because there is less room for error.

The verification process

I'm going to walk you through the verification process. The first stage is to complete a readiness review. We've got a QR code at the end. You can go in and check your readiness for verification in terms of the scope, boundaries, and reporting data you may have available for a specific reporting period. That will help deduce whether you're ready for verification or not. If you're not, there are a number of options to complete training, to look at working with Pulsora to be able to capture all the relevant information so you can report on it.

When you are ready for verification, there's a pre-verification process, which is an informal meeting that goes through the scope and boundaries, the data that's required, etc. Then we go into stage one and stage two verification audits.

In the initial pre-verification stage, it's important that we understand the level of assurance: whether limited or reasonable is going to be the right option for you. That determines the number of days of the audit, the evidence required, and who's going to be involved in your project team for submitting that information.

We then move on to stage one, which is looking for the key documents we need to validate your claims. These are things like your inventory and the intended use of that, the significance policy, and other key documents like the dissemination policy. During stage one, we also cover the Scope 1 and 2 emissions, including the quantification methodology, any estimates and assumptions, the factors you're using, any uncertainty approaches, plus the exclusions and justifications. Again, this is all about being completely transparent.

Finally, we move on to stage two, where we get into the Scope 3 emissions. This is where we find it does take a bit longer, because this can be quite a challenging area for a lot of organizations in getting accurate information from their supply chain. Stage two also covers any reduction initiatives and forecasts, and we can provide guidance about those forecasts in relation to your current GHG inventory.

Finally, there is a peer review completed independently at Carbonology. A report is produced documenting the verification opinion statement, and there is also a verification certificate issued, and a verification mark which can be used on marketing collateral like websites, but not on products, because this isn't a verification of products. It's for the organization's GHG emissions.

Q&A: How do we know if greenhouse gas data is ready for third-party assurance?

In terms of whether it's ready, you need to go through Scopes 1, 2, and 3, and be confident in the quantification of the reporting. If you're using software like Pulsora, you'll be able to clearly see from the reports and outputs whether that's ready or not. Ultimately, you're looking for a defined reporting period, a 12-month reporting period, whether that's a calendar year or tying in with your financial year. Some organizations decide to complete two reporting periods, even three in some cases if they're going back in time.

Q&A: Is there a CARB reporting template for SB 253?

For 253, there is no official guideline aside from being aligned to the GHG Protocol. However, if you are starting out and looking for something to follow, they have released a sample template, an Excel file, which has several specific fields you can fill out, such as boundary-related details, emissions factors details, and the actual Scope 1, 2, and 3 emissions numbers. Feel free to check that out on CARB's website. We'll send that out in one of the follow-up emails along with the webinar recording. It's meant to be much more of a starting point. It's not a specific framework that's going to be reviewed against in any way.

The market is driving demand for verification

One of the interesting things I found in my research, doing my master's of research on the drivers and impact of greenhouse gas emissions reporting and disclosures, is that it seems to be the markets that are actually driving the demand for reporting disclosures and verification, which was quite a surprise. When I first started doing the research two years ago, I was fully expecting it to be driven by regulations, but it's really interesting to see that organizations are swaying towards the markets. One of the key reasons is financial. More often than not, organizations get access, unlocks access to sustainable finance through sustainable-linked loans, green bonds, investor opportunities, plus all the ESG rating programs like CDP and EcoVadis. The vast majority are actually reporting voluntarily. Even though there's been a pause on the regulations at the moment, that doesn't seem to be stopping people from doing the reporting and disclosures, because at the end of the day, we need to get to net zero. We need to be able to demonstrate evidence of that. There is a big credibility gap in terms of what organizations are claiming and what they're actually doing in terms of their results. So it seems to be the markets that are pushing for proof.

It's really interesting, the increase in company value if companies are demonstrating commitments through SBTi. There was a study over eight years of the S&P 500. It identified that those organizations that committed to reducing their carbon emissions increased their company valuation by 4%. But for those that actually put their money where their mouth was and got independent verification, the company valuation increased by 10%. That is really quite significant. It was 367 companies out of the 500 that actually verified, and they were the ones that had the increase in company valuation. So although there has been a setback over the last week with the California regs, I think it is just temporary. It's only going to be a matter of time.

And the setback doesn't apply to 253. In terms of your emissions accounting, Scope 1 and 2 are still expected to be completed by August 10th of 2026.

Q&A: Does SB 253 require reporting for all Scopes?

In the first year, you are only required to submit data regarding Scope 1 and 2. In subsequent years, starting in 2027 on your 2026 data, you will be asked to submit data on Scope 3 as well. However, there's evolving guidance with regards to which Scope 3 categories are expected to be included, and the materiality process or documentation of the decision-making for which of those categories will be included. That will be something interesting to keep an eye out for at the next CARB quarterly meeting. They said they would meet in the spring to discuss a little bit more on that.

Closing

I want to thank everyone for being here and especially Mel, for joining us and sharing all of this wisdom on the assurance process. It was really valuable and interesting to hear. Thank you all so much, and we'll be sharing the recording and some follow-up resources via email. Have a great day.

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