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ARTICLE · 22 SEPTEMBER 2026

Climate Disclosure Update: California Issues Updated Regulations And Guidance For GHG Emissions Reporting

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California's Air Resources Board has released significant modifications to its greenhouse gas emissions reporting regulation, deferring the first reporting deadline to November 10, 2026, and clarifying key requirements for companies doing business in California with over $1 billion in annual revenue. The updates provide additional flexibility for 2026 reporting while enforcement of the Climate-Related Financial Risk Act remains paused pending federal litigation.

United StatesEnvironment
Peggy Otum
Peggy Otum
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Shannon Morrissey
Molly R. Calhoon Silva
Molly R. Calhoon Silva
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Jarrod Ingles
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On July 27, 2026, the California Air Resources Board (CARB) released modifications to its proposed regulation implementing California’s corporate greenhouse gas (GHG) emissions reporting requirements under the Climate Corporate Data Accountability Act (SB 253). CARB is now reviewing comments on those proposed modifications following a 15-day public comment period. CARB announced that the modifications are intended to clarify regulatory requirements rather than to alter the scope of covered entities or their reporting obligations.

As we previously reported, CARB withdrew its initial regulation from review by the California Office of Administrative Law (OAL) in late June and signaled that it would issue an updated version for the abovementioned 15-day comment period.

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