In 2023 the California Legislature passed several bills mandating greenhouse gas (GHG) emissions reporting and creating new disclosure obligations for businesses marketing or selling voluntary carbon offsets in California. (See New California GHG Disclosure Laws Taking Effect in 2024) On December 16, 2024, the California Air Resources Board (CARB) issued a notice opening a public Solicitation for Information to inform implementation of Senate Bill (SB) 253 (Wiener, Statutes of 2023) and SB 261 (Stern, Statutes of 2023), both as amended by SB 219 (Wiener, Statutes of 2024). According to CARB, this solicitation is “crucial for gathering important information from a wide range of stakeholders, helping CARB to develop effective approaches for the implementation of these bills.”
SB 253 and SB 261 require business entities formed under the laws of California, the laws of any other state or the District of Columbia, or under an act of Congress that are doing business in California to report specified GHG emissions and climate-related financial risks. Specifically, SB 253, the Climate Corporate Data Accountability Act, requires companies with more than $1 billion in annual revenue to annually report direct and indirect GHG emissions, including indirect emissions from consumed energy, upstream and downstream sources. SB 261, the Climate-Related Financial Risk Act, requires companies with more than $500 million in annual revenue to biennially report any climate-related financial risks they have identified and measures adopted to reduce and adapt to those risks.
On or before February 14, 2025, interested parties may submit answers to questions outlined in the Solicitation for Information. CARB’s questions address definitions (e.g., how to interpret “doing business in California”), implementation and enforcement (e.g., how to identify all covered businesses), how to administer and control costs of data collection, and how to meet other specific statutory requirements. Interested parties may also submit “any additional feedback that respondents feel is important for staff to consider regarding the implementation of SB 253 and SB 261.” CARB requests that comments be submitted electronically via the designated portal.
Contact: Lynn Haug or Brian Biering
