Policy and regulation
In the United States, the regulatory landscape for climate disclosure experienced a moment of intense legislative realignment during the summer of 2026, culminating in critical adjustments to California's landmark Corporate Climate Data Accountability Act (SB 253). Authorized to cover US-organized entities doing business in California with annual global revenues exceeding $1 billion, SB 253 represents one of the most stringent and far-reaching corporate climate disclosure mandates globally, impacting thousands of multinational corporations15.
Throughout July 2026, the California Air Resources Board (CARB) advanced modified regulations designed to ease the immediate compliance burden on the private sector and ensure orderly market adoption. The most consequential adjustment was the formal deferral of the inaugural Scope 1 and Scope 2 reporting deadline. Originally scheduled for August 10, 2026, the deadline was officially pushed to November 10, 2026, providing reporting entities a vital three-month extension to finalize their greenhouse gas inventories, navigate complex corporate boundaries, and establish auditable data collection protocols15.
To facilitate this first cycle, CARB launched a voluntary 2026 Report Intake Platform and clarified the enforcement environment. Utilizing a December 2024 Enforcement Notice, the agency stated it would exercise significant enforcement discretion for the 2026 cycle. This leniency allows entities to submit Scope 1 and Scope 2 emissions based on data they already possessed or were actively collecting at the time the notice was issued16. Entities that lacked data collection infrastructure are not expected to submit quantitative emissions data for 2026; instead, they are encouraged to submit a formal "statement of non-reporting" outlining their good-faith compliance efforts, the limitations of their current systems, and their roadmap for future reporting16. Limited assurance (third-party auditing) remains optional for the 2026 report, transitioning to a mandatory requirement beginning in 202715.
Crucially, CARB announced the explicit deferral of Scope 3 (value chain) emissions reporting for the 2026 cycle, aligning with the statutory language that focuses the inaugural year solely on direct operational emissions17. Looking ahead to the 2027 regulatory framework, CARB used a July 21 public workshop to signal a strategic intent to align heavily with the widely accepted GHG Protocol standards to ensure international interoperability and reduce corporate ambiguity16. Furthermore, the proposed 2027 Scope 3 requirement has been significantly narrowed from the standard fifteen categories to just five critical categories: purchased goods and services, fuel- and energy-related activities, waste generated in operations, business travel, and employee commuting22.
These adjustments reflect a pragmatic compromise by Californian regulators. The agency recognizes the immense data engineering, legal, and operational challenges inherent in mandatory emissions reporting—particularly Scope 3 calculations—opting for a phased, good-faith ramp-up rather than punitive enforcement that could trigger widespread corporate resistance or legal injunctions, similar to the ongoing federal litigation stalling other climate mandates17.
Summary of publicly reported developments, current at the time of writing. Not investment, legal or tax advice. Verify every figure against the instrument in force before relying on it.
