CARB Publishes Preliminary List of Companies Potentially Subject to SB 253 and SB 261
Summary
The California Air Resources Board (CARB) on 24 September published a preliminary roster of entities it believes may fall under SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Disclosure), as amended by SB 219. CARB compiled the list by cross-referencing the California Secretary of State registry with Dun & Bradstreet revenue data and applying scoping definitions discussed at public workshops. The spreadsheet is available on CARB’s website.
CARB staff estimate roughly 2,600 companies exceed the SB 253 threshold (global revenues > $1 billion) and about 4,100 exceed the SB 261 threshold (global revenues > $500 million). The preliminary list includes large firms across technology, retail, energy, financial services and manufacturing, and targets entities doing business in California regardless of headquarters location.
CARB stresses the list is not definitive: inclusion does not equal a final reporting obligation, and omission does not preclude responsibility. CARB requests entities validate their status via a survey and notes that final regulatory guidance is still pending. First reports under SB 261 are due 1 January 2026.
Key Points
- CARB released a preliminary list (24 Sept) of entities that may be subject to SB 253 and SB 261.
- Method: cross-reference California Secretary of State records with Dun & Bradstreet revenue data and CARB’s conceptual scoping definitions.
- Estimated scope: ~2,600 companies for SB 253 (>$1bn global revenue) and ~4,100 for SB 261 (>$500m global revenue).
- List is preliminary — inclusion or omission is not a final legal determination; CARB requests entities complete a validation survey.
- Key near-term action: inaugural SB 261 reports due 1 January 2026; companies should assess applicability now.
- Recommended preparatory steps: determine applicability, document non-reporting rationales, choose a reporting framework (e.g. TCFD or ISSB), strengthen governance, collect GHG/data, run scenario analysis, and consult legal advisers.
- CARB signals a “good faith” approach for enforcement if entities document applicability assessments, but scrutiny and stakeholder pressure are likely to increase.
Context and Relevance
This development significantly advances California’s climate disclosure regime and broadens regulatory reach to many companies that do business in the state. For corporate counsel, sustainability leads and finance teams, the timing is urgent: reporting frameworks, data collection and governance processes must be in place quickly to meet reporting deadlines and to withstand investor and stakeholder scrutiny.
Why should I read this?
If your business might sell into California, pull in over $500m globally or just don’t want surprise compliance headaches, this is worth a five-minute read. The list isn’t final, but the deadlines are real — and getting your paperwork and data ducks lined up now will save stress (and risk) later.
Author style
Punchy: this is a big compliance moment. If you’re on the preliminary list, treat it like a red flag — get legal advice and start reporting prep. If you’re close to the thresholds, document your analysis so you can show you acted in good faith.