The first reporting deadline for California’s Climate Corporate Data Accountability Act (SB 253) is looming. On November 10, 2026*, large firms doing business in California that have annual revenues exceeding $1 billion are required to submit their Scope 1 and 2 emissions for the previous fiscal year to the California Air Resources Board (CARB).
*Extended from August 10th in a June 2026 announcement
Do companies under $1 billion need to prepare?
Yes. In 2027, these large businesses will also be required to disclose their supply chain emissions (Scope 3). This means that many businesses with <$1 billion in revenue are not off the hook. While these smaller businesses are not obligated to report emissions to CARB, they can expect the large businesses in their supply chains to begin requesting emissions data from them as part of the larger businesses’ future Scope 3 reporting obligations.
If you are responsible for reporting to CARB or preparing to respond to these data requests from your partners, now is the time to understand what’s changing and how to begin preparing.
Businesses must publicly disclose Scope 1 and Scope 2 emissions by November 10, 2026. These disclosures will be required annually. Starting in 2027, reporting of Scope 3 (upstream and downstream) emissions will begin. These emissions must be disclosed no later than 180 days after a business discloses its Scope 1 and Scope 2 emissions in 2027. Moving forward, Scope 3 emissions disclosures will also be required annually.
Large businesses that do not set themselves up to comply with the law and smaller businesses that fail to prepare to fulfill data requests from large supply chain partners in the coming months will be at a disadvantage.
Am I required to report to CARB?
If a business has ALL of the characteristics listed below, it is required to report to CARB:
• “Does business” in California
• Was formed in the U.S.
• Has total annual revenues exceeding $1 billion*
*Determined by taking the lesser of the business’ two previous fiscal years of revenue
Understanding Scopes 1, 2, & 3
Penalties for Noncompliance
CARB will oversee the reporting program and collect fees to fund the initiative and impose financial penalties for non-compliance in future years. When imposing nonfiling, late filing, and other assorted penalties, CARB must consider all relevant circumstances. This includes a violator’s past and present compliance and whether the violating business took good faith measures to comply with requirements. There is a maximum penalty of $500,000 per business per reporting year.
Businesses are granted some leniency regarding Scope 3 emissions. Between 2027-2030, penalties for Scope 3 reporting will only be imposed on businesses that are required to report and fail to do so. In other words, fees will not be issued for business’ misstatements regarding Scope 3 emissions during that time period as long as filed disclosures were made with a reasonable basis and in good faith.
What are the latest updates?
CARB Resolution 26-1, which was signed and certified in April 2026, provides several key updates. In addition to approving reporting deadlines outlined in the initial regulations, this resolution clarifies the program fee structure, proposing a flat fee structure that will be applied equally to all reporting businesses.
Additionally, 26-1 addresses CA’s related Climate-Related Financial Risk Act (SB 261). It notes that due to an injunction issued in November 2025, CARB is currently halting the enforcement of SB 261. This announcement has no bearing on the SB 253 reporting requirement and deadlines. To stay up to date on SB 253, we recommend going straight to the source.
Why this matters for the pet industry
SB 253 applies to many of the pet industry’s largest pet product manufacturers and retailers.
Even if your business is not required to report to CARB, now is the time to start internal conversations about how you’re going to respond to emissions data requests from partners along your supply chain as they prepare to meet their 2027 Scope 3 reporting requirements.
One business’ Scope 3 emissions are another business’ Scope 1 and Scope 2 emissions. For example when a large company needs transportation and distribution data for Scope 3, that data is within their logistics partner’s scope 1 emissions. Consequently, smaller players are likely to be asked to provide emissions data to larger companies required to report to CARB.
As with many sustainability regulations, companies both large and small can approach this as a compliance obligation OR see it as an opportunity to deepen relationships across the value chain and a nudge to collect and use data to reduce emissions over time.
What Do I Need to Do Now?
1. Determine Applicability and Maintain Records
First, assess if your business will be required to report emissions using the checklist above. Businesses must retain records demonstrating whether they meet revenue and “doing business in California” thresholds for five years and provide these records to CARB upon request.
2. Measure Your Business’ Scope 1 & Scope 2 Greenhouse Gas Emissions
GHG measurement must be performed strictly in accordance with Greenhouse Gas Protocol standards. This involves calculating direct emissions from owned or controlled sources (Scope 1) and indirect emissions from purchased electricity, steam, heating, or cooling (Scope 2).
Reporting entities, in particular, must also:
3. Obtain Third-Party Assurance
Starting in 2027, businesses must obtain an assurance engagement from a qualified, independent, third-party assurance provider. For the next few years, the assurance for Scope 1 and Scope 2 emissions reporting only needs to be performed at a “limited assurance” level. This will escalate to a “reasonable assurance” level in 2030.
4. File Initial Scope 1 and Scope 2 Disclosures
Businesses required to report must publicly disclose their Scope 1 and Scope 2 emissions on or before November 10, 2026. This first disclosure must cover the “applicable preceding fiscal year” (generally the previous calendar year).
5. Pay the Annual Implementation Fee
Beginning in 2026, CARB will issue a written fee determination notice by September 10. Businesses must remit this payment to CARB within 60 days to avoid late fees.
6. Begin preparing for Scope 3 Disclosures
Starting in 2027, businesses required to report must begin disclosing their Scope 3 emissions. Scope 3 disclosure will be due no later than 180 days after disclosing Scope 1 and Scope 2 emissions for the prior fiscal year. While Scope 3 assurance is not required initially, CARB may establish third-party assurance requirements for Scope 3 reporting by 2027.
In Closing
Climate legislation like SB 253 are necessary to drive change at scale and transition the U.S. toward a greener economy. By mandating emissions reporting from large businesses, SB 253 promises to improve emissions transparency and lay the groundwork for better risk management that will benefit consumers, investors, and companies themselves.
Ready to take the next step?
If your business is required to report to CARB or preparing to meet the emissions data requests of your customers and partners, the Pet Sustainability Coalition is here to help. Join a coalition of companies advancing sustainability, and get the support you need to stay ahead of what’s next.