California climate disclosure software for CARB reporting requirements under SB 253 and SB 261

Last updated August 2026. California climate disclosure applies to companies above $1 billion in total annual revenue that do business in California, which is SB 253 and covers emissions, and to companies above $500 million that do business in California, which is SB 261 and covers climate risk. CARB administers both. The first Scope 1 and Scope 2 emissions report is due November 10, 2026, and November 10 becomes the recurring annual deadline after that. SB 261 enforcement has been stayed by the Ninth Circuit since November 18, 2025 and the appeal is still undecided. SB 253 is not stayed.

The rules moved twice this year, which is why a large share of the guidance still circulating is wrong. CARB deferred the first deadline from August 10 to November 10, 2026, and then on July 27, 2026 published a package of modifications that changed the Scope 3 phase-in, the fee schedule, the insurer exemption and the enforcement language. The comparison table further down sets out what changed, because the differences are the parts most likely to be sitting in your compliance calendar with the old dates.

SB 253 applies to any US-organized partnership, corporation, limited liability company or other business entity with total annual revenue above $1 billion that does business in California. Revenue is total, not California revenue, and the test is applied at the individual entity level rather than to a consolidated group as a whole. SB 261 uses the same structure with a $500 million threshold.

Two things trip companies up. The first is that the revenue figure is global, so a Texas or Ohio company with no California operations to speak of can be well inside the threshold. The second is the nexus half of the test, covered in the next section, which is far easier to meet than people assume. If you are working out whether you are covered at all, the threshold question is worked through in more detail in our note on whether SB 253 applies under $1 billion.

The statutes never define it. CARB's regulation fills the gap by borrowing California's existing franchise-tax test, and that is the single most useful fact on this page, because almost nobody publishes the number. An entity is doing business in California if it is organized or commercially domiciled in the state, or if its California sales exceed a threshold the Franchise Tax Board indexes every year: $735,019 for 2024 and $757,070 for 2025, applied as the lesser of that figure or 25% of the entity's total sales. Property and payroll factors work the same way, at $75,707 for 2025.

Put the two halves together and the practical bar is low. A company at $1.2 billion of global revenue with three quarters of a million dollars of California sales is in scope, with no office, no employees and no property in the state. Verification runs off California tax filings, so this is not a judgment call you get to make loosely: the numbers are already on a return somewhere in your tax department.

Less than most companies fear. The first report is Scope 1 and Scope 2 emissions only, expressed in metric tons of CO2e, with the source data and the assumptions behind them. There is no Scope 3 in the 2026 filing, and there is no assurance requirement in the 2026 filing. CARB has also said it will not pursue enforcement against entities making good-faith compliance efforts in the first cycle, and the July 2026 modifications moved that discretion out of a policy notice and into the regulation itself.

This is the table to check your own compliance calendar against. Each of these changed after most published guidance was written, and the fee row in particular is still wrong in a lot of places, including, until this update, on this site.

One caveat on how firmly to rely on this. The modifications went out on a 15-day notice whose comment window closed on August 11, 2026, and the package still required approval from the Office of Administrative Law when this page was written. The direction is unambiguous and the detail is specific enough to plan against. Check the final adopted text before you write any of it into a control document.

Five, from reports filed in 2027: category 1 purchased goods and services, category 3 fuel and energy related activities, category 5 waste generated in operations, category 6 business travel and category 7 employee commuting. The remaining ten categories are voluntary, reported under the GHG Protocol Scope 3 Standard if you choose to include them. CARB's stated reason for picking these five is that they have the most established data sources and the most mature quantification methods.

For each required category you disclose the category name, number and description, the quantification and accounting methods used, the data types used, total CO2e, an explanation for any exclusions, and the percentage of the figure calculated using primary data. That last item is the one to design for now, because it is a property of how you collect data rather than something you can add at the end. The full fifteen-category framework sits on our Scope 3 emissions guide, and the calculation methods are in how to calculate Scope 3 emissions.

CARB had to price its own rule before it could adopt it, which produced the only per-company benchmark this market has. The figures below come from CARB's Standardized Regulatory Impact Assessment. Read them as the cost of the whole obligation, including internal staff time and a separate independent assurance firm, and not as a vendor invoice.

The gap between the first two rows is worth a second look: adding Scope 3 costs an estimated $13,954 a year, not another full inventory. That matches practice, because the boundary work, the factor policy and the evidence trail are built once and then reused. The program fee is separate again, a flat amount charged identically to every covered entity rather than scaled to revenue, which CARB earlier estimated near $3,106 for an SB 253 reporter and $1,403 for an SB 261 reporter. The full cost breakdown is in SB 253 compliance cost, and software pricing across the category is on carbon accounting software cost.

SB 261 is on the books, but its enforcement has been stayed since November 18, 2025, when the Ninth Circuit granted an injunction pending appeal. The court heard oral argument on January 9, 2026 and had not ruled as of August 2026. SB 253 was not enjoined and remains fully in force.

The sensible planning posture is to keep preparing the SB 261 climate risk report while the appeal is pending. A ruling could lift the stay at short notice, and the report is a narrative document that takes weeks to assemble properly. It is also worth noting the reverse risk: an appellate decision could reach SB 253 as well, so neither outcome should be treated as certain.

Strip away the category marketing and the November 10 filing is an accounting problem. You need every emitting activity in the reporting year identified, classified to the right scope, multiplied by a documented emission factor, and traceable back to the document that proved it happened. The regulation asks for source data and assumptions, which means the number alone is not the deliverable.

Our classifier takes the accounts payable export you already produce and turns spend lines into a scoped, sourced inventory with the invoice attached to each figure. The narrower statute-specific view is on SB 253 reporting software, the assurance requirements are in SB 253 assurance requirements, the enforcement exposure is in SB 253 penalties, and if you are starting late there is a 90-day plan. The wider US picture, including the SEC rule, is on climate disclosure software, and if you would rather hand the work to a firm, that trade-off is set out on carbon accounting services.