California climate disclosure laws: CARB announces Scope 3 phase in, rescinds exemption for insurers and codifies 2026 enforcement discretion - White & Case LLP
California's CARB has announced a phased implementation of Scope 3 emissions reporting, rescinded an exemption for insurers, and codified enforcement discretion for 2026 under SB 253 and SB 261.
Aforeworn detected this change in the ESG & Climate Disclosure space on August 4, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Public companies, large private filers, insurers, and sustainability consultants operating in California or subject to SB 253/SB 261. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Not specified in the provided text; monitor CARB announcements for specific dates.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors ESG & Climate Disclosure continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
Scope 3 reporting will be phased in, insurers are no longer exempt, and CARB has formalized its discretion to enforce in 2026.
Who it affects
Public companies, large private filers, insurers, and sustainability consultants operating in California or subject to SB 253/SB 261.
What you must do
Review current GHG inventory and reporting processes to prepare for Scope 3 inclusion and ensure compliance with SB 253/SB 261.
Deadline
Not specified in the provided text; monitor CARB announcements for specific dates.
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- New California Climate-Related Disclosure Mandates Will Require Corporate Reporting Ahead of - and Broader than - the SEC | Thought Leadership | September 2023 - Baker Botts