California SB 253 – Climate Corporate Data Accountability Act

California law requiring US-based companies with more than $500 million in annual revenue that do business in the state to publish a climate-related financial risk report every two years, following the TCFD framework or an equivalent. The Ninth Circuit enjoined enforcement while the Chamber of Commerce appeal is pending, so CARB has not enforced the 1 January 2026 deadline. Companies may post reports voluntarily to a CARB docket opened 1 December 2025.

Enforcement

Mandatory by statute; enforcement suspended by court injunction

Effective date

Statutory first report due 1 January 2026 and every two years after; CARB is not enforcing that date and will announce an alternate reporting date after the appeal is resolved

Covered entities

US companies doing business in California with revenue >$500m

California runs the most extensive set of state EPR laws in the US, anchored by SB 54, which makes producers of single-use packaging and plastic food service ware fund collection, recycling and source reduction through Circular Action Alliance as the state's PRO. CAA filed its program plan in June 2026 and CalRecycle must act on it by 1 January 2027. Separate laws cover paint, mattresses, carpet, batteries, pharmaceuticals and sharps, and textiles (SB 707, with Landbell USA approved as the PRO in March 2026).

Enforcement

Mandatory

Effective date

SB 54 signed 30 June 2022; permanent regulations effective 1 May 2026; Circular Action Alliance submitted the program plan 15 June 2026, with CalRecycle approval and program start due on or before 1 January 2027; first Plastic Pollution Mitigation Fund payment due 1 March 2027; full recyclability and 65% recycling rate by 1 January 2032; textiles (SB 707): producers had to join the PRO by 1 July 2026, PRO needs assessment due March 2027, approved plan required by July 2030 and full implementation in 2031

Covered entities

Producers of single-use packaging and plastic food service ware sold in California; paint, mattress, carpet, battery and battery-embedded product, pharmaceutical and sharps, and textile producers under each product-specific stewardship law

New York bill modeled on California SB 253 that would require large companies doing business in the state to disclose Scope 1, 2 and 3 emissions each year, with limited assurance from 2028 and reasonable assurance from 2032. Civil penalties would reach $100,000 per day, capped at $500,000 per reporting year. The Senate passed S9072A in February 2026; the Assembly has not acted.

Enforcement

Mandatory if enacted

Effective date

If enacted as passed by the Senate: DEC regulations by 31 December 2027; Scope 1 and 2 reporting from 2028; Scope 3 from 2029; act takes effect 180 days after it becomes law

Covered entities

Partnerships, corporations, LLCs and other business entities with total revenues above $1 billion that do business in New York