Proposed Concepts for Subsequent SB 253 Rulemaking Presented at the July 21, 2026 CARB Virtual Public Workshop

Summary

SIFMA ¹ provided comments to the California Air Resources Board ("CARB") to inform the implementation of the Climate Corporate Data Accountability Act ("SB 253"), as amended by the Greenhouse gases: climate corporate accountability: climate-related financial risk Act ("SB 219").

Excerpt

Many SIFMA members are actively working to comply with new climate disclosure regulations being implemented by regulators worldwide. In addition to SB 253, many firms have already been voluntarily reporting their greenhouse gas ("GHG") emissions, often using widely adopted international voluntary frameworks such as the Task Force on Climate-Related Financial Disclosures ("TCFD") recommendations, the Greenhouse Gas Protocol (the "GHG Protocol"), the Sustainability Accounting Standards Board ("SASB"), World Economic Forum Stakeholder Capitalism Metrics and the GRI standards. SIFMA members also use climate-related information disclosed by others to inform investment and business decisions. Given this experience, SIFMA is well-positioned to offer insights on how CARB regulations under SB 253 can produce reliable disclosures while minimizing the burden on reporting companies. Given the importance of the topics addressed at the July 21, 2026 CARB Virtual Public Workshop (the "July 21 Workshop") and in an effort to continue its ongoing productive engagement with CARB ² , a working group of SIFMA members has prepared a response addressing the matters discussed at the July 21 Workshop to inform CARB's regulatory approach to the subsequent SB 253 rulemaking.

CARB's presentation at the July 21 Workshop and associated materials (the "July 21 Workshop Materials") make clear that CARB's approach is intended to maximize alignment with the GHG Protocol and interoperability with other reporting regimes, while providing regulatory certainty and a structured phase-in of reporting obligations to support the development of a robust and workable reporting regime. SIFMA supports those key principles, including:

• CARB's effort to promote regulatory certainty (and comply with its statutory obligations and obligations under the California Administrative Procedures Act) through incorporating the GHG Protocol as currently in effect;
• Phased implementation of requirements to support the development of a reliable reporting framework, including CARB's December 2024 Enforcement Notice, CARB staff's guidance that assurance will not be required in the first year of reporting, and the proposed phase-in of Scope 3 categories over time beginning with the five most commonly reported categories in 2027;
• The establishment of a single November 10 reporting deadline applicable to Scope 1, Scope 2 and Scope 3 emissions; and
• CARB's commitment to interoperability with other mandatory reporting regimes, including the International Sustainability Standards Board's ("ISSB") IFRS S2 Climate-related Disclosures standard and the European Sustainability Reporting Standards ("ESRS"), which will reduce fragmentation and avoid duplicative reporting for multinational entities.