Proposed Concepts for Subsequent SB 253 Rulemaking
Summary
SIFMA 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
The matters addressed at the SB 253 Public Workshop on the California Corporate Greenhouse Gas Reporting Program, held on March 23, 2026 (the “March 23 Public Workshop”), are complex and highly technical issues that go to the heart of SB 253. A three-week comment period concluding on April 13 is insufficient for matters of this importance and complexity. It is infeasible to prepare a comprehensive and informed response in this limited timeframe. While SIFMA acknowledges that CARB published a statement on its website noting that “It would be most helpful to get cost-related comments by April 13. Informal comments will be received until June 1,” that statement is unclear as to whether comments received after April 13 on topics other than costs will be considered or receive the same level of engagement and attention from CARB staff as those received earlier. 1
As such, given the importance of the topics addressed at the March 23 Public Workshop and in an effort to continue its ongoing productive engagement with CARB 2 and provide input to help inform further development of those matters, a working group of SIFMA members has prepared a preliminary response addressing the matters discussed at the March 23 Public Workshop.
Given the limited time provided between March 23 and April 13 to review and digest the proposals shared at the March 23 Public Workshop, our review remains ongoing. SIFMA may have further comments. We plan to continue to engage with CARB on these topics. To facilitate that engagement and provide other members of the public with a meaningful opportunity to comment on the matters addressed at the March 23 Public Workshop, we strongly encourage CARB to clarify that comments received on all topics addressed at the March 23 Public Workshop between April 14 and June 1 will be given the same level of consideration as comments received on or before April 13.
Many SIFMA members are actively working to comply with new climate disclosure regulations being implemented by regulators worldwide. In addition to these requirements, many firms have already been voluntarily reporting their greenhouse gas (“GHG”) emissions and climate-related financial risks, often using international voluntary frameworks such as the TCFD recommendations, the GHG Protocol, SASB standards, World Economic Forum Stakeholder Capitalism Metrics, and 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 the information provided at the March 23 Public Workshop regarding proposed concepts for subsequent SB 253 rulemaking can produce reliable disclosures while minimizing the burden on reporting companies.
- That ambiguity was further heighted by the fact that the statement posted by CARB on April 6, 2026 initially read: “It would be most helpful to get staff comments by April 13. Informal comments will be received until June 1” and was later changed to refer to “cost-related comments.”
- SIFMA has made six other CARB submissions regarding the implementation of SB 253 and the California Climate-related Financial Risk Act (“SB 261”). The first was written comments to CARB on March 8, 2025, providing a discussion of key principles that should inform CARB’s approach to regulation under SB 253 and SB 261, along with specific responses to select questions included in CARB’s Information Solicitation (the “March 8th SIFMA Letter”), available here. The second, on August 14, 2025, was a document summarizing key takeaways from SIFMA’s June 17 virtual meeting with CARB staff. The third was a letter submitted by SIFMA on August 29, 2025 addressing CARB’s proposal to publish a list of companies that CARB believes would be required to report under SB 253 and SB 261 under the approach discussed by CARB staff at the August 21, 2025 virtual public workshop on SB 253, SB 261 and SB 219. The fourth was a letter submitted by SIFMA on September 11, 2025 addressing the August 21, 2025 Climate Disclosure Workshop, available here. The fifth was a letter submitted by SIFMA on October 27, 2025 addressing the draft reporting template CARB provided for Scope 1 and Scope 2 GHG emissions pursuant to SB 253 (the “October 27th SIFMA Letter”), available here. The sixth was a letter submitted by SIFMA on February 9, 2026 addressing CARB’s Proposed Corporate Greenhouse Gas Reporting and Financial Risk Disclosure Regulation (the “February 9th SIFMA Letter”), available here.