CARB Seeks Feedback on Preliminary List of Entities for California’s New Corporate Emissions Reporting Regime

The California Air Resources Board (CARB) has published a Preliminary List of Reporting/Covered Entities under its forthcoming California Corporate Greenhouse Gas (GHG) Reporting Program, as authorized by SB 253 (the Climate Corporate Data Accountability Act). The list is intended to identify companies that may be required to report emissions and climate-related financial disclosures under the emerging regulatory regime.

CARB is now inviting stakeholders to provide feedback on the preliminary list via a voluntary survey tool. Entities that believe they are included incorrectly, or that they should be included but are not, are encouraged to respond. Companies may also use the survey to indicate if they qualify for exemptions from coverage under the law.

In a public workshop held in August, CARB explained that the preliminary list draws on existing sources such as business registries, revenue databases, and public filings and may not include every entity that should fall under the program’s coverage. The agency aims to validate and refine the list through stakeholder input ahead of formal rulemaking.

CARB’s final proposed regulations are expected by December 2025. The survey feedback will be one of several ways for affected parties to influence key definitions—such as what counts as “doing business in California,” how revenue is measured, and which exemptions should apply.

Firms that operate in or have ties to California and approach or exceed the revenue thresholds (e.g. > US $1 billion for SB 253, > US $500 million for SB 261) should consider reviewing the preliminary list and completing the survey, even if they believe they may later qualify for exclusion.