The Nickel Report

On Friday, October 10, the California Air Resources Board (CARB) posted for public comment a draft template for reporting Scope 1 and Scope 2 greenhouse gas (GHG) emissions pursuant to California SB 253, the Climate Corporate Data Accountability Act (Act). Along with the draft template, CARB also posted an explanatory memorandum.

This draft guidance from CARB is potentially helpful for reporting entities to understand what CARB will require in future reporting years, especially given that the legislative deadline for CARB to issue implementing regulations passed several months ago, as explained in our previous post. In recent months, CARB has been focused on presenting concepts for its regulations and identifying entities subject to reporting, as explained here.

The comment period will remain open until October 27, 2025. Interested parties can submit comments on the online docket or via email to climatedisclosure@arb.ca.gov.

Overview of the Climate Corporate Data Accountability Act

SB 253 is aimed at creating transparency for the public regarding reporting of GHG emissions for certain larger businesses. To that end, it requires “reporting entities” to disclose their GHG emissions in a format accessible to the public. Reporting entities are broadly defined as entities with an annual revenue exceeding $1 billion that “do business in California.” Inaugural reporting of Scope 1 and 2 emissions starts next year, despite the fact that CARB is still working on implementing regulations to clarify requirements. CARB is expected to set the exact reporting deadline in these upcoming regulations.  

The New Draft Template

The explanatory memorandum states that CARB intends for the draft template to “streamline reporting, especially for entities disclosing GHG emissions for the very first time.”^[1] Use of the template is, however, voluntary for the 2026 reporting cycle.

The draft template lists 74 mandatory fields and 100 optional fields for future reporting years. It contains fields for expected types of information, like general organization identification information and contact information. It also includes several technical questions tied to the emission disclosures requirements of SB 253, necessitating extensive data collection and verifiable calculations to answer. The questions are categorized, and the data type (i.e., text or numeric) is identified. The table organizes Scope 1 emissions disclosures by mobile, stationary, or fugitive sources.

One of the key issues related to SB 253 is how an organization is defined for reporting purposes – i.e., where to draw the line around the entity that is reporting the information. The template asks questions on how the entity defines its organizational boundaries, leaving entities with a choice of which approach to use, of those provided for under the Greenhouse Gas Protocol (i.e., equity share, financial control, or operational control approach). The template also asks questions about the entity’s emission reductions associated with use of renewable electricity or renewable gas. The majority of the optional questions are variations of the mandatory emissions questions but focused on a specific greenhouse gas. There is also an optional question allowing the entity to explain any limitations or uncertainties in the report.

Again, use of the template for reporting in 2026 is voluntary. CARB noted that it will publish further guidance on reporting as part of the regulatory process

[1] California Corporate Greenhouse Gas Reporting Program: Scope 1 and Scope 2 Emissions Draft Reporting Template, California Air Resources Board (Oct. 10, 2025) available here.