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.
- SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate on legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org. SIFMA appreciates the assistance of Michael Littenberg and Marc Rotter of Ropes & Gray LLP in the preparation of this response.
- SIFMA has made seven 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 (the “September 2025 Letter”), 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. The seventh was a letter submitted by SIFMA on April 13, 2026 addressing CARB’s proposed concepts for the subsequent SB 253 rulemaking presented at the March 23, 2026 CARB Virtual Public Workshop (the “April 13th SIFMA Letter), available here.