& Securities

With less than three months until the deadline for the first greenhouse gas emissions reports under California’s Corporate Greenhouse Gas Reporting Program (SB 253), in-scope entities should be preparing for disclosure and monitoring ongoing rulemaking efforts that will affect first year and subsequent year reports. This alert provides updated Questions and Answers on climate-related disclosures required under California SB 253 and SB 261. These reflect proposed rulemaking relating to alignment with the Greenhouse Gas Protocol standards and guidance, Scope 3 reporting and assurance requirements discussed at a California Air Resources Board public workshop held on July 21, 2026, revised regulatory text published by CARB on July 27, 2026, and CARB staff’s first two “listening sessions” held on August 12, 2026 and August 5, 2026.