New Greenhouse Gas Reporting Requirements for Large Companies

New Green House Gas (GHG) Reporting Requirements for Large Companies Start on August 10, 2026

Who is required to report?

Partnerships, corporations, limited liability companies, or other business entities formed under state or US law with total annual revenues in excess of $1 Billion that do business in California.

“Revenue” is defined under section 25120(f)(2) of the California Revenue and Taxation Code and will be based on the lesser of the entity’s two previous fiscal years of revenue.

How do I know if I’m subject to the rule?

The California Air Resources Board (CARB) has made a list of who needs to report, but it is not comprehensive and your company is responsible for reporting even if you are not on the list – you can access it here:

Is there a cost associated with reporting?

Yes, CARB will issue a bill on or by September 10, annually to those required to report.

When do I report:?

Reports are due annually to CARB on August 10, starting in 2026.

What is the time period covered by a report?

• If a company’s fiscal year ends on or before February 1: Example: Fiscal year ends January 30, 2026 – The company reports on GHG emissions from January 30, 2025, to January 30, 2026.
• If a company’s fiscal year ends after February 1: Example: Fiscal year ends June 30, 2026 – The company reports on GHG emissions from June 30, 2024, to June 30, 2025.

What do I report?

Scope 1 Emissions: GHG emitted from sources that a company owns or directly controls, regardless of location, including, but not limited to, fuel combustion activities.

Scope 2 Emissions: GHG emissions from electricity, steam, heating, or cooling purchased or acquired by a reporting company, regardless of location.

Can I use reports I’m doing already?

Yes, if a company already submits annual Scope 1 and Scope 2 emissions through a voluntary program or to another regulatory program, that company may submit that same information to CARB.

What else is required?

Scope 1 and Scope 2 emissions must be verified by an independent third party at a limited-assurance level beginning in 2026 and annually thereafter until 2030. Beginning in 2030, the verification level becomes more stringent (reasonable-assurance level) for annual reports from then on. A list of CARB certified GHG Verifiers and organizations can be found here.

This seems complicated, what has CARB said about enforcement?

CARB has committed to using “enforcement discretion” for the reports due on August 10, 2026. They have repeatedly said that it is their intention to recognize good faith efforts from companies to report.

Can the rule be stopped or changed?

Because the rule’s requirements were mandated by Senate Bill (SB) 253 (Wiener, 2023), CARB has limited flexibility in implementing it. UCON is working with CARB to express our members concerns about the rule.

Is there other reporting that will be required later?

Yes, in 2026 CARB will develop reporting rules and deadlines for Scope 3 emissions starting in 2027.

Additionally, there is currently a court injunction which has paused reporting under SB 261, pending the result of litigation. That Bill requires CARB to develop rules and deadlines for Climate Related Financial Risk Reports.

Where can I get more information?

There is more information available for CARB here.

For immediate questions, contact Gus Flores, UCON’s Director of Government Relations, (916) 347-6849