Although the SEC climate rules never became effective, the California GHG emissions disclosure and assurance requirements apply to a significant number of public and private U.S.-based companies (including U.S. subsidiaries of non-U.S. companies) that do business in California, and the first reports could be due as early as June 30, 2026 (subject to final implementing regulations slated for December).

Below are nine questions to help companies unpack the latest guidance, assess remaining open issues and determine how to prepare.

What is Required and When?

Beginning in 2026, each public and private U.S.-based company that is deemed to be a Reporting Entity [1] must submit its greenhouse gas (GHG) emissions report and assurance verification covering the prior fiscal year to the California Air Resources Board (CARB). Although the implementing regulations and guidance are not yet finalized, CARB’s current proposal is for Reporting Entities to publish and file their first GHG emissions report covering fiscal year 2025 by June 30, 2026. In the current proposal, everything required for the report (both the emissions data and the assurance verification) would need to be submitted by this date. We note this deadline received substantial criticism during the working group session on August 21, 2025, and CARB encouraged feedback to be submitted through the comment process, citing that they did not want to set any “impossible deadlines.”

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