California Issues FAQs On Corporate GHG Reporting And Climate Risk Disclosure Requirements

On July 9, 2025, the California Air Resources Board (CARB) released Frequently Asked Questions (FAQs) to help guide companies in complying with the state's new Corporate Greenhouse Gas (GHG) Reporting and Climate-Related Financial Risk Disclosure Programs. Specifically, the FAQs address certain regulatory development, applicability, reporting requirements, deadlines, and key definitions under SB 253 and SB 261.

As discussed in greater detail in our prior California climate disclosure advisory, SB 253 applies to US-based entities with $1 billion or more in annual revenue that do business in California and requires such entities to annually disclose Scopes 1, 2 and 3 greenhouse gas (GHG) emissions for the prior fiscal year. SB 261 applies to US-based entities with $500 million or more in annual revenue that do business in California and requires such entities to publish on their own website a biannual climate-related financial risk report that discloses (i)