The Nickel Report

The California Air Resources Board (CARB) held a public workshop on July 21, 2026, to preview regulatory concepts for a forthcoming proposed rule to implement the California Corporate Greenhouse Gas Reporting Program (SB 253) requirements beginning in 2027. CARB did not specify a timeframe for release of the proposed rule, which will be subject to a 45-day public-comment period.

CARB’s regulatory concepts for SB 253 reporting, detailed in the July 21 staff presentation, are grounded principally in the Greenhouse Gas Protocol (GHG Protocol), including its Corporate Standard, Scope 2 Guidance, and Scope 3 Standard. Staff also emphasized “interoperability” with other reporting regimes, including IFRS S2 and the EU Corporate Sustainability Reporting Directive, with the stated aim of reducing duplicative reporting burdens.

To implement both the mandatory requirements and certain recommendations of the GHG Protocol, CARB staff plans to propose that reporting entities include specific data points in their SB 253 disclosures, such as:

• Quantification methods and related uncertainty;
• Consolidation approach for organizational boundaries;
• Missing data elements and substitute data or estimation methods used to quantify emissions in place of the missing data;
• Data exclusions and their basis; and
• Changes to GHG quantification or accounting methods made from the previous reporting year or during the current reporting period.

CARB staff also previewed its proposal for separate reporting of:

• Biogenic CO₂ from the combustion, consumption, or biodegradation of biomass and biomethane, to be reported separately from Scope 1, 2, and 3 totals; and
• Voluntary investments in emissions reductions or removals.

Further, structural or methodological changes that cumulatively alter base-year emissions by more than 5 percent would trigger recalculation of affected prior-year data.

For reporting Scope 3 emissions, CARB staff previewed a phased approach beginning in 2027, which would require reporting for five common Scope 3 emission categories: (1) Purchased Goods and Services, (2) Fuel- and Energy-Related Activities, (3) Waste Generated During Operations, (4) Business Travel, and (5) Employee Commuting. Reporting of the other ten GHG Protocol Scope 3 categories would be voluntary for the time being. For every reported Scope 3 category, entities would disclose the category and covered activities, accounting methods and data types, total emissions, exclusions, and the percentage calculated from primary data—along with the quantification method used for that primary-data calculation.

Beginning with 2027 reports, and consistent with SB 253, CARB’s forthcoming regulations will require limited assurance for Scope 1 and 2 emissions, including separately reported biogenic CO₂ emissions, from an independent third party. CARB staff propose to codify accepted assurance standards and assurance report requirements in its regulations, which are listed on slides 33 and 34 of the staff presentation, respectively.

Anticipated Next Steps

Based upon the staff presentation, we expect the following over the next few weeks and months:

• Rulemaking actions, exact timing to be determined:
  • CARB will issue for additional 15-day public comment amendments to its “initial rulemaking” that was previously presented to the Board. CARB has indicated that it is working as quickly as possible to issue its revised proposal to allow sufficient time for compliance efforts in advance of the November 10, 2026, compliance deadline for covered entities to submit their first SB 253 reports (covering Scope 1 and 2 emissions).
  • CARB will issue another proposed rulemaking to implement SB 253 reporting requirements, as previewed during today’s workshop, for a 45-day public comment period.
• By September 1, 2026: CARB will issue additional guidance materials to support 2026 Scope 1 and 2 emissions reporting, including a voluntary online intake platform for fee contact information and GHG emissions reporting and an accompanying guidance document and instructional video.
• August 5 through September 9: CARB will hold sector-specific listening sessions to allow an exchange of information and additional input from stakeholders on upcoming reporting obligations.