SB 253 vs SB 261: which California climate disclosure law applies to your company

SB 253 and SB 261 are California's two climate disclosure laws, they are frequently confused, and they ask for completely different things. SB 253 makes you publish a measured greenhouse gas inventory. SB 261 makes you publish a narrative about how climate change threatens your business and what you are doing about it. Different thresholds, different deliverables, different deadlines, and right now, very different enforcement status.

The short version: if your company has more than $1 billion in annual revenue and does business in California, you are almost certainly in scope for both. If you are between $500 million and $1 billion, you are in scope for SB 261 only.

The difference in one table

	SB 253	SB 261
Name	Climate Corporate Data Accountability Act	Climate-Related Financial Risk Act
Revenue threshold	More than $1 billion total annual revenue	More than $500 million total annual revenue
What you file	A measured number: Scope 1 and Scope 2 emissions, with Scope 3 from 2027	A narrative: climate-related financial risks and the measures you are taking
How often	Annually	Every two years
Deadline	November 10, 2026, deferred from August 10, 2026	January 1, 2026 statutory date, currently not enforced
Assurance	Limited assurance not required for the 2026 submission	No assurance requirement
Who usually owns it	Finance or operations: it is a measurement exercise	Finance, legal and risk: it is a disclosure exercise

Which one applies to my company?

Start with revenue, and be careful about which revenue. Both laws test total annual revenue, not California revenue, and both use the lesser of your previous two fiscal years. So a company with $1.4 billion in global revenue and one office in San Jose is in scope for SB 253 on its global number. Revenue earned inside California is not the test. Doing business in California is the trigger, and total revenue is the threshold.

Both laws apply to entities formed in the United States that do business in California. "Doing business in California" is a broad standard, and companies routinely discover they meet it through sales activity or property they had not thought about in this context. If you are near either threshold, this is a question for your counsel and not for a blog post, ours included.

Why is SB 261 not being enforced right now?

Because it is in litigation. SB 261's statutory deadline was January 1, 2026, but a Ninth Circuit injunction is in play, and CARB has said it will not enforce that deadline while the appeal proceeds. CARB has indicated it will set an alternate reporting date once the courts resolve the matter.

The mistake would be reading "not enforced" as "not happening". The obligation is on the books, the litigation concerns how it is applied rather than whether the topic goes away, and the report itself (climate risk, governance, and what you are doing about it) takes months to write properly because it requires opinions from people who are busy. Companies treating the pause as a reprieve rather than a deadline extension are the ones who will scramble. Watch the docket, keep drafting.

Which is harder to produce?

SB 253, without much argument. A climate risk narrative is a writing and governance exercise: you convene the right people, work through physical and transition risks, and describe them honestly. It is real work, and the finance team that already turns the ledger into board-ready financial statements is usually the right team to own it, because the risk report has to sit alongside those statements without contradicting them.

SB 253 is a data problem, and data problems do not respond to effort applied late. You need every fuel purchase, every utility bill, every refrigerant service record, each mapped to a scope with a documented emission factor and a trail back to the source document. From 2027 you also need Scope 3, which means your entire value chain, and which for most companies is the large majority of the footprint. There is no version of that which gets done in the two weeks before it is due.

Do they overlap at all?

Usefully, yes. A credible SB 261 risk narrative leans on the numbers an SB 253 inventory produces: you cannot say much about your transition risk exposure without knowing where your emissions actually sit. A company whose footprint is concentrated in purchased goods has a supply chain transition risk. A company whose footprint is concentrated in the use of its sold products has a product risk, and probably a revenue risk. The inventory tells you which conversation you are having.

So the sequencing is not "two projects". It is one data project that feeds two filings. Build the inventory properly, and the risk narrative gets easier to write and much harder to argue with.

What to do about it this quarter

If you are over $1 billion: your SB 253 clock runs to November 10, 2026, and the work is finding and classifying data you already own. We wrote a week-by-week version of that in the 90-day plan, and the tooling side is on SB 253 reporting software.

If you are between $500 million and $1 billion: you have SB 261 only, the deadline is unsettled, and the right move is to draft the risk report and keep an eye on the litigation. It is also the right moment to build a screening emissions inventory even though nobody is currently requiring one from you, because the risk narrative is weak without it, and because thresholds in this area have a habit of coming down.

Either way the foundation is the same: a classified ledger with an evidence trail from every figure back to the line that produced it. That is what our carbon accounting software does, and you can run the classifier on your own data in the demo before you talk to anybody. If your exposure is European rather than Californian, CSRD reporting software covers that regime instead.

SB 253 and SB 261 facts here describe California law and CARB rulemaking as published in July 2026, including the pending Ninth Circuit litigation affecting SB 261. Dates and requirements can change while the rulemaking is open. Confirm with CARB, and take legal advice from someone who is actually your lawyer.