The Path Ahead for Companies

California Climate Disclosure: The Path Ahead

A practical readiness roadmap for SB 253 & SB 261 compliance in 2026

As the deadlines for California’s climate disclosure laws draw closer, many companies are asking: What can we do today to get ready? This guide outlines key steps to take now through 2030 to prepare for SB 253 and SB 261.

2025 Readiness Checklist

Companies that will be subject to California’s climate disclosure requirements in 2026 should already be in preparation mode. If you haven’t started yet, now is the time. Below isa checklist to get you started.

1. Measure 2024 Scope 1 & 2 Emissions

• Treat this as a “dry run” for the formal 2026 reporting year.
• Use this exercise to prepare your systems, identify gaps, and test your processes.

2. Document Your Process

• Begin building your “single source of truth”—your emissions inventory and methodology.
• Include boundaries, data sources, assumptions, and calculation methods.

3. Test Assurance

• Consider conducting a limited assurance trial on your 2024 Scope 1 & 2 data.
• Engage an audit provider early to understand the process and expectations.

4. Begin Drafting SB 261 Narratives

• Start building qualitative disclosures aligned with the TCFD four pillars:
  • Governance
  • Strategy
  • Risk Management
  • Metrics & Targets
• Reference peer disclosures in your industry for examples and best practices.
• Involve stakeholders from legal, finance, and enterprise risk management early in the process.

📍 2026: Your First Reporting Year

By the end of 2026, companies should expect to:

• ✅ Submit assured Scope 1 and 2 emissions (from 2025 data) through the CARB portal (SB 253).
• ✅ Publish your SB 261 disclosures on your company website. This may be part of your sustainability or annual report and should include your TCFD-aligned narrative.
• ✅ Optional but encouraged: Conduct a Scope 3 test run to prepare for 2027 disclosure.

SB 253 requires platform-based emissions submission, while SB 261 disclosures simply need to be made publicly available, typically via your website.

📍 2027: First-Time Scope 3 Reporting

• ✅ Measure and publish Scope 3 emissions for the first time.
• ✅ Scope 1 and 2 data must again be assured at the limited level.
• ✅ Scope 3 data is reported, but not yet subject to assurance.

📍 Looking Ahead to 2030

• ✅ Scope 3 emissions will become subject to limited assurance for the first time.
• ✅ Scope 1 and 2 emissions will require reasonable assurance, a higher level of audit scrutiny.

💡 Why Framework Alignment Matters

Most of California’s disclosure requirements, especially under SB 261, are based on the TCFD, which has now been absorbed into the ISSB (International Sustainability Standards Board). Aligning with ISSB standards now can:

• Help you future-proof your disclosures
• Simplify global compliance efforts
• Ensure consistency across jurisdictions like the EU, UK, Canada, Japan, and Singapore

In Summary: Your Disclosure Roadmap

Final Thoughts

California’s climate laws are part of a broader shift toward standardized, transparent climate disclosure. Taking action now, by building emissions inventories, engaging auditors, and drafting TCFD-aligned narratives, can help reduce risk and position your company for long-term regulatory and stakeholder confidence.

Thank you for joining Persefoni’s California Climate Disclosure course. Our team is here to support you with updates and guidance every step of the way.

🎓Request Your Certificate of Completion

Congratulations on completing our California SB 253 and SB 261 workshop! To receive your official Certificate of Completion, please fill out the form below with your details. Ensure all information is accurate to avoid any delays in processing your certificate.

Please note: Certificates will be issued within two weeks of submission.