The last month brought major milestones in both California and Brussels. CARB published its preliminary company list and a draft emissions-reporting template, marking another step forward in the preparation of “the 200s” (SB 253, SB 261, and SB 219). CARB also announced a postponement of the rulemaking procedure for these bills—the process for formally adopting regulations and opening them for public comment—though confirmed that the statutory reporting deadlines remain unchanged.
In Brussels, the European Parliament’s Legal Affairs Committee settled its position on the sustainability Omnibus, setting up trilogue negotiations that will shape CSRD and CS3D reforms through 2026.
California publishes preliminary company list and confirms existing deadlines, even while rulemaking is delayed
At the end of September, the California Air Resources Board released a preliminary list of roughly 4,160 companies it believes are in scope for SB 253 and SB 261—California’s new climate disclosure laws for large businesses. The list identifies US companies with more than $1 billion in annual revenue (SB 253) or $500 million (SB 261) that “do business” in the state, drawing on Secretary of State records, tax filings, and commercial business databases.
The list is a preliminary estimate only. Many companies that should be included seem to be missing, and some that appear may not actually be in scope. CARB has acknowledged these data limitations and made clear that companies remain responsible for determining whether they meet the thresholds, regardless of their inclusion in the list. For companies with entities they believe are incorrectly included, CARB has opened a short survey to submit corrections or clarify inclusion.
After releasing the list, CARB also announced that it is postponing the start of its rulemaking process—focused mainly on designing the fee structure that will finance both programs. This rulemaking effort does not change the SB 261 reporting timeframe, which is set by law as January 1, 2026, and CARB again pointed companies to the resources it has already published, including the SB 261 checklist and SB 253 template, to get ready.
For more information on the list read our blog.
California releases draft emissions reporting template for SB 253
On October 10, CARB released a draft template for reporting scope 1 and 2 greenhouse gas emissions under SB 253. The template covers (1) organizational information, (2) third-party verification, (3) inventory boundaries, (4) scope 1 and 2 disclosures, (5) methodology, (6) de minimis/minor sources (emissions excluded based on materiality thresholds), (7) California’s Mandatory Reporting Regulation (MRR), and (8) emissions reductions where applicable. It also asks for at least one intensity metric, and includes optional base year fields to support trend comparisons.
Use of the template—provided in Excel with free text and dropdown boxes—is optional for the first reporting year and is intended simply to streamline reporting, especially for those disclosing GHG emissions for the first time.
CARB is accepting feedback on the template through October 27, particularly on key areas including: reporting by emission source versus gas; whether to restrict entities to one boundary approach; and how emissions reduction initiatives should be captured. Feedback can be submitted through CARB’s public docket or emailed to climatedisclosure@arb.ca.gov.
EU Parliament committee finalizes its position in advance of Omnibus negotiations
In Brussels, all eyes have been on the European Parliament’s Legal Affairs Committee which has finalized its position on the Corporate Sustainability Omnibus—a package revising the CSRD and CS3D directives—before the Parliament moves to trilogue negotiations with the Council and Commission.
The center-right European People’s Party (EPP) had been exploring options with both a left-leaning and right-leaning bloc, with the former ultimately prevailing. This centrist “von der Leyen majority,” which passed the committee 17-6, proposes that EU entities would be in scope for CSRD if they have over 1,000 employees and €450 million turnover. This is in line with the Council’s proposal, though it deviates from the Commission’s which proposed 1000 employees and either turnover of €50 million or a balance sheet of €25 million. While trilogue negotiations will determine the final revenue threshold, the new employee threshold of 1,000 employees will likely result in 6-12,000 entities remaining in scope.
On CS3D—the rule requiring companies to identify human-rights and environmental risks in their supply chains—the Parliament is proposing a threshold of 5,000 employees and €1.5 billion turnover, consistent with the Council. The adopted position retains the obligation to adopt transition plans, now through reasonable efforts, and proposes a holistic “risk-based” approach to due diligence, rather than entity-based, aiming to reduce demands on smaller companies within supply chains.
The vote clears a major procedural hurdle but begins a complex next phase. The Parliament’s position must first pass a plenary vote—expected October 23—before moving to trilogue negotiations with the Commission and Council, expected to begin in November and conclude in the first half of 2026. As part of that, watch out for discussions on non-EU reporters. Currently, subsidiaries in the EU caught by the new thresholds are due to report by 2028 (on 2027 data), while reporting for non-EU parent companies has remained at 2029.
