Are You On the List? CARB Identifies 4,000+ Companies Impacted by SB 253 & SB 261
Yesterday, the California Air Resources Board (CARB) released a preliminary list identifying more than 4,000 U.S. companies potentially subject to the state’s new climate disclosure laws, SB 253 and SB 261. This is a pivotal moment for corporate climate risk disclosure — and a signal that the “grace period” is ending.
In this post, we explain what was released, why it matters, how the rules work, and how The CF Team can help your organization navigate these laws.
What CARB Published — And What It Means
The Preliminary List
CARB’s newly released list is not final or exhaustive, but it provides the first public snapshot of which firms might fall under the scope of SB 253 and SB 261. The list is based on revenue and business-in-California criteria developed using databases such as California’s Secretary of State and commercial data firms (e.g. Dun & Bradstreet). (BDO)
But as CARB has made clear, companies remain responsible for assessing their own status even if they are not on the list.
Key Features & Dates
SB 253 (Climate Corporate Data Accountability) applies to companies with global revenues over $1 billion doing business in California. It requires annual public reporting of GHG emissions (Scopes 1, 2, and eventually 3) beginning in June 2026 for Scope 1 & 2, with Scope 3 reporting due starting 2027.
SB 261 (Climate-Related Financial Risk Disclosure) applies to companies with revenues above $500 million doing business in California, requiring biennial disclosure of climate-related financial risk under frameworks like TCFD or IFRS S2. The first reports are due at the start of 2026.
Why It Matters: Key Implications for Businesses
As we’ve mentioned in previous posts, these laws have big implications for your business.
Compliance Burden & Timing: These laws introduce a significant compliance burden. Firms will need to build or enhance emissions accounting systems, climate risk assessment processes, assurance frameworks, and cross-functional coordination (e.g., finance, legal, operations, sustainability). The deadlines are tight, and many organizations will need to act fast — even if they are not yet on the CARB list.
Scope 3 Data = The Real Hurdle: Reporting Scope 3 emissions will force companies to engage upstream and downstream partners, assess data gaps, and build new data pipelines. In many industries, this is the hardest piece of the puzzle. CARB’s law also includes future requirements for assurance of Scope 3 emissions — a high bar for verification and auditability.
Financial Risk Disclosure Integration: SB 261 requires companies to embed climate-related risk into financial narratives in line with established frameworks. That means management, boards, and financial teams must integrate climate into their strategy, stress tests, scenario planning, and disclosures.
Reputation, Markets & Liability: Transparency is becoming a differentiator. Investors, customers, and regulators will increasingly expect climate disclosure. Firms failing to comply may face reputational, investor, or legal pressure.
How The CF Team Can Help You Navigate This
At The CF Team, we’re already guiding clients through the new California regime. Here’s how we support:
Scoping & Gap Assessment
We help you determine whether you qualify under SB 253 and/or SB 261 based on your revenue, operations, and activities in California.Roadmap & Strategy Development
We build tailored roadmaps: emissions inventory design, climate risk analysis, assurance planning, and disclosures.Technical Execution & Integration
We manage or advise on tools, data systems, partner coordination, scenario analysis, and narrative development.Governance & Stakeholder Management
We help integrate these mandates into governance frameworks, board oversight, and stakeholder communication.Review, Assurance & Quality Control
We help prepare your data and disclosure for third-party assurance, ensuring your outputs are robust and defensible.
If you’d like to dive into the legal and technical underpinnings, you can start with our explainer: “California’s SB 253 & SB 261”
You can also browse our library of blogs and insights on topics like GHG accounting, climate risk, and disclosure: The CF Team Insights
What to Do Now
Review the CARB list to see if you appear (or are likely to appear).
Run a self-assessment vs. revenue and “doing business in California” criteria.
Begin collecting emissions and risk data now — even if incomplete, it’s better to start early.
Monitor CARB’s upcoming guidance (templates, definitions, comment windows).
Engage with experts (like us) to build your disclosure program with confidence.
The disclosure wave is coming — and it’s better to ride ahead of it than to chase it. If you want us to help you map your next steps, we’re ready when you are. Get in touch.
