CARB Publishes Additional 2026 Reporting Guidance and Opens Voluntary Reporting Platform

This year’s reports under SB 253, California’s corporate greenhouse gas emissions reporting requirement, are due on November 10. With 71 days to go, the California Air Resources Board has published new guidance intended to assist reporting entities in preparing and submitting their 2026 reports. CARB’s voluntary intake platform also is now live. The guidance and platform are discussed in this post.

The guidance is consistent with prior CARB guidance and does not add new requirements.

CARB Reaffirms Enforcement Notice

In its December 5, 2024 Enforcement Notice and subsequently, CARB has indicated that it will exercise enforcement discretion for this year’s reports, allowing reporting entities to submit Scope 1 and Scope 2 GHG emissions for their prior fiscal year based on information they already have or were collecting when the December 2024 notice was issued. The Enforcement Notice is further discussed in this Ropes & Gray post.

The guidance indicates that, if a reporting entity was not collecting data or planning to collect data at the time the Enforcement Notice was issued, it is not expected to submit Scope 1 and 2 data this year.

Submitting Reports

Voluntary Intake Platform

CARB has developed a voluntary 2026 report intake platform to help streamline fee implementation and this year’s reporting. The platform can be accessed here.

The intake platform provides optional fields to voluntarily submit Scope 1 and 2 emissions reports to CARB. Even if a reporting entity does not submit its report through the platform, it can use the platform to provide its contact information to CARB to provide billing information for fee invoicing. 

The platform allows for a single submission on behalf of multiple reporting entities (e.g., a global-level report on behalf of multiple subsidiary reporting entities). There is an option for the fee payment to be combined or paid individually by each reporting entity.

A reporting entity that does not plan to report emissions data in 2026 pursuant to the December 2024 Enforcement Notice also may notify CARB via the intake platform.

All uploaded emissions reports and statements of non‑reporting will be made public.

CARB has released a video tutorial on the platform.

Email Submissions

As noted above, use of the intake platform is voluntary this year. Entities may instead submit data by emailing [email protected].

Fees

CARB will send 2026 invoices on or before December 10. As indicated in the Initial Regulation, payment will be due within 60 calendar days from the date of CARB’s invoice.

Reporting Formats

Yesterday’s guidance reiterated prior CARB guidance on reporting format options for this year:

• Submit an existing annual report that includes Scope 1 and 2 GHG emissions.

• Submit existing Scope 1 and 2 data reported to other programs or voluntary initiatives.

• Use CARB’s October 10, 2025 draft Scope 1 and 2 template for reporting data. The template is further discussed in this Ropes & Gray post.

• Submit a statement of non-reporting on company letterhead indicating that the company was not collecting Scope 1 and 2 emissions data as of December 5, 2024 and was not planning to do so. Entities can submit the statement using the intake platform or the [email protected] email inbox.

Additional Detail Encouraged

In the guidance, CARB encourages reporting entities to provide additional details in this year’s reports to help qualify the reported emission numbers and provide important context. Examples noted include descriptions of methodologies, data sources, global warming potential values, emission factors, organizational boundaries, disaggregated emission data by category and gas and any assumptions used. CARB’s draft reporting template has examples of questions connected to these types of information.

Scope 2 Emission Factor Options

Use of a specific emission factor dataset is not required this year. CARB acknowledged that reporting entities commonly use emission factors from the EPA’s Emissions & Generation Resource Integrated Database (eGRID) for Scope 2 calculations and that the EPA has not released eGRID 2024 on its usual timeline. 

The guidance indicates that reporting entities may use the most recent official EPA eGRID release (eGRID 2023) or, if preferable, the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative, which was generated from the EPA’s publicly available source code. Companies may also elect to use alternative credible emission factor sources. Companies are encouraged to identify the emission factors used and their sources. 

Assurance

The guidance reiterates that, under CARB’s first-year enforcement discretion, it will accept submissions that have not been assured. 

Reporting Requirements for 2027 and Beyond

CARB noted its second rulemaking process relating to reporting requirements for 2027 and subsequent years is underway. Among other things, this rulemaking will address GHG accounting methodologies, reporting deadlines, assurance requirements and reporting formats. The second rulemaking is further discussed in this Ropes & Gray post.

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