California SB-253 Climate Disclosure Calculator (>$1B Revenue) | Coverage, Scope 1/2/3 Timeline & SB-261 Risk Disclosure

What this calculator determines

The calculator resolves whether an entity is covered by California’s two climate-disclosure laws from two inputs — total annual revenue and whether it does business in California — and returns the disclosures each law requires and the deadlines that attach. It is a coverage and scoping tool: it answers “which of these laws applies to me, and what do I owe and by when,” not “what are my emissions.” Building the actual inventory is a separate step, fed by the underlying Scope 1, Scope 2, and Scope 3 calculators.

Two laws, two thresholds, two deliverables

The California SB-253 and SB-261 climate-disclosure regime is really two statutes that travel together. SB-253, the Climate Corporate Data Accountability Act, requires greenhouse-gas emissions reporting above a $1 billion revenue threshold. SB-261, the Climate-Related Financial Risk Act, requires a climate-risk report above a $500 million threshold. A company above $1 billion typically falls under both and files a combined dual obligation; a company between $500 million and $1 billion falls under SB-261 only. The tool separates the two so neither obligation hides the other.

Why coverage turns on California nexus, not headquarters

Both thresholds combine a revenue figure with “doing business in California.” Neither law cares where a company is incorporated or headquartered — a business based anywhere in the United States is covered if it meets the revenue test and has sufficient California activity. CARB’s February 2026 regulation pins the revenue measure to the gross-receipts concept in the California Revenue and Taxation Code, so the threshold is read against a defined tax-code figure rather than a novel one. This is the single most-missed point in scoping the laws.

Am I covered? The $1B and $500M tests

Coverage is a two-step test applied to each law in turn: does the entity meet the revenue threshold, and does it do business in California. Because the thresholds differ, an entity can be covered by SB-261 alone, by both laws, or by neither. The calculator applies both tests and returns the governing combination.

SB-253 / SB-261 coverage thresholds and deliverables. The revenue triggers ($1,000M SB-253, $500M SB-261) and the SB-261 biennial cadence are queryable Master Brain fields read live by the calculator engine (reporting.sb_253_261.sb253.threshold.annual_revenue_usd_m, …sb261.threshold.annual_revenue_usd_m, …sb261.cadence.years), anchored to the SB-253 / SB-261 statutory text as amended by SB-219. These are outside_scopes framework markers — used for coverage logic, never summed into a CO₂e total. The prose values are hardcoded per the Calculator JS-runtime rule; the engine is the live read path. Both thresholds combine with a “doing business in California” test. Source CA_SB253 / CA_SB261, MasterBrain v2026.203.

SB-253 — the $1 billion emissions threshold

An entity with total annual revenue above $1 billion that does business in California is a reporting entity under SB-253 and must report its greenhouse-gas emissions following the GHG Protocol Corporate Standard. Scope 1 and Scope 2 come first; Scope 3 follows from the 2027 cycle. The threshold is a bright line on revenue — there is no float test, no public-company requirement, and no exemption for private companies, which is a sharp contrast with the federal SEC rule’s filer tiers.

SB-261 — the $500 million risk-report threshold

An entity above $500 million in revenue doing business in California is a covered entity under SB-261 and must publish a climate-related financial-risk report describing its climate risks and the measures it has adopted to reduce and adapt to them. The report follows the TCFD framework or an equivalent such as IFRS S2, and is published biennially. SB-261 does not require an emissions inventory — it is a risk-disclosure obligation, distinct from SB-253’s quantitative reporting.

“Doing business in California” — the trap

The phrase carries the coverage weight that catches companies off guard. An out-of-state company with no California office can still be doing business in California through sales, property, or payroll in the state above the relevant tax-code thresholds. Because the revenue figure is the entity’s total annual revenue — not its California revenue — a company with modest California activity but large global revenue can be fully covered. Scoping on California-only revenue, or assuming a non-California headquarters means exemption, is the most common way companies wrongly conclude they are out of scope.

Reporting timeline and phase-in

SB-253 phases in by scope, and the dates are set by CARB regulation rather than by the statute alone. The first reporting deadline applies to Scope 1 and Scope 2; Scope 3 follows a year later, with the framework still being written. SB-261’s first deadline is the subject of the Ninth Circuit stay. The table below states the current position; treat every date as confirmable against CARB given the active rulemaking and appeal.

SB-253 / SB-261 reporting timeline. The first-report years (2026 for Scope 1 and 2, 2027 for Scope 3) are read live by the engine from the Master Brain; the specific 10 August 2026 calendar deadline is set by CARB’s initial regulation (adopted 26 February 2026, pending Office of Administrative Law clearance) and is hardcoded with source, as the Master Brain carries the year only. The Scope 3 framework remains in CARB rulemaking. SB-261’s 1 January 2026 statutory deadline is stayed under a Ninth Circuit injunction (granted November 2025); CARB will set an alternate date after the appeal. Sources: CARB initial regulation and filings; Ninth Circuit docket. Status and calendar dates are hand-reviewed — the Master Brain carries no live deadline or status field. Confirm against CARB before relying on any date (verified 4 June 2026).

Scope 1 and 2 first — the August 2026 deadline

CARB’s initial regulation establishes 10 August 2026 as the first-year deadline for Scope 1 and Scope 2 emissions reporting under SB-253. The reporting year covered depends on the entity’s fiscal year, and CARB’s December 2024 enforcement notice grants good-faith relief for this first cycle: companies demonstrating a good-faith effort to prepare their disclosures are not penalised for incomplete first-year reporting. This grace period recognises that building a complete Scope 1 and 2 inventory under audit-grade controls takes time.

Scope 3 from 2027 — framework still being written

Scope 3 reporting begins from the 2027 cycle. CARB is still in pre-rulemaking on the Scope 3 framework — organisational boundaries, accounting methods, and which of the fifteen Scope 3 categories phase in first are not yet final. A statutory safe harbor protects good-faith, reasonable-basis Scope 3 disclosures from penalty through 2030, so the early Scope 3 obligation is real but cushioned. This is the defining feature of SB-253 relative to the federal SEC rule, which adopted no Scope 3 requirement at all.

The assurance ramp

SB-253 requires third-party assurance over the reported emissions, ramping from limited assurance to reasonable assurance over time, with Scope 1 and 2 assured before Scope 3. The exact assurance calendar sits within CARB’s ongoing rulemaking and is not yet finalised, so the calculator describes the direction of travel — limited first, reasonable later — rather than pinning specific years. Provision for assurance early: the controls and evidence trail a limited-assurance review needs are easier to build alongside the first inventory than to retrofit.

The obligation that Washington adopted and then abandoned, California enforces.
SB-253 is the rare US climate mandate that reached a filer’s desk — and it carries the Scope 3 requirement the federal rule would not.

What you must report

The two laws ask for different things. SB-253 wants numbers — a greenhouse-gas inventory across scopes, prepared under the GHG Protocol and third-party assured. SB-261 wants a narrative — a structured report on climate-related financial risks and the company’s response, aligned to TCFD or IFRS S2. A company covered by both files both.

SB-253 — the emissions inventory

Reporting entities disclose Scope 1, Scope 2, and (from 2027) Scope 3 emissions, measured under the GHG Protocol Corporate Standard, expressed in carbon-dioxide equivalent. The inventory is reported annually and made publicly accessible, and it must carry third-party assurance at the level CARB’s rulemaking sets for the year. Because the methodology is the GHG Protocol, the same inventory work feeds any other GHG-Protocol-based obligation a company carries — there is no separate SB-253 accounting standard to learn.

SB-261 — the climate-risk report

Covered entities publish a climate-related financial-risk report describing their material climate risks — physical and transition — and the measures adopted to reduce and adapt to them. CARB’s guidance directs alignment with the TCFD framework or an equivalent such as IFRS S2, the ISSB standard that succeeded TCFD when that body dissolved in 2024. The report is published on the entity’s website biennially. It is a disclosure of risk and response, not an emissions count, which is why a $500 million-to-$1 billion company can owe a SB-261 report without owing a SB-253 inventory.

How the calculator works

You enter total annual revenue and confirm whether the entity does business in California, and the calculator applies each law’s revenue threshold and nexus test, then returns the governing coverage and the disclosures and deadlines that attach. It applies the thresholds in the order the statutes set, so the SB-261 obligation surfaces independently of the SB-253 one.

Worked example — a covered retailer

This example is illustrative and shows coverage logic, not an emissions computation — the tool scopes obligations from revenue and nexus, and the emissions inventory itself is built separately. Consider a US retailer headquartered in Texas with total annual revenue of $3.4 billion and substantial store sales in California.

Resolving coverage

Total revenue of $3.4 billion is above both the $1 billion SB-253 threshold and the $500 million SB-261 threshold, and the California store sales establish “doing business in California.” The Texas headquarters is irrelevant to coverage. The retailer is a reporting entity under SB-253 and a covered entity under SB-261 — the combined dual obligation.

What is due, and when

Under SB-253, the retailer must report Scope 1 and Scope 2 emissions by 10 August 2026, add Scope 3 from the 2027 cycle, and carry third-party assurance on a phasing calendar CARB is still setting — with good-faith relief available for the first cycle and a Scope 3 safe harbor through 2030. Under SB-261, it must publish a TCFD- or IFRS-S2-aligned climate-risk report; that obligation’s first deadline is currently stayed by the Ninth Circuit injunction, so the retailer may file voluntarily on CARB’s open docket while the appeal is pending.

What it does not change

The retailer’s federal position is unaffected — the SEC climate rule is dormant and imposes nothing. California is where this company’s live US climate-disclosure obligation sits. The Scope 1 and Scope 2 inventory it builds for the August 2026 SB-253 deadline is the same inventory that feeds its SB-261 risk quantification and any voluntary investor disclosure, so the work is not duplicated across the two laws.

SB-253 vs SEC, IFRS S2 and CSRD

SB-253 is one of several climate-disclosure regimes a large company may face at once, and they are frequently confused. The clearest way to scope a company’s full obligation is to see where SB-253 sits relative to the dormant federal rule, the international IFRS S2 standard, and the EU’s CSRD — because the same emissions inventory often satisfies several of them.

Climate-disclosure regimes compared. SB-253 is a mandatory US state regime with a Scope 3 requirement; the federal SEC climate-disclosure rule is stayed and dropped Scope 3; IFRS S2 and CSRD are live where adopted and reach Scope 3 where material. Triggers and statuses stated from each regime’s governing instrument as of June 2026.

Penalties, assurance and enforcement

SB-253 carries real financial penalties, but the first cycle is cushioned by CARB’s good-faith relief and the Scope 3 safe harbor. SB-261’s penalty regime exists but is not currently enforceable because of the Ninth Circuit stay. The penalties are set by statute; the Master Brain does not carry a penalty field, so these figures are stated from the statute and hand-reviewed.

SB-253 / SB-261 penalty ceilings. SB-253 administrative penalties may not exceed $500,000 in a reporting year (Health & Safety Code §38532, per the SB-253 statutory text); SB-261 penalties are capped at $50,000 per year. CARB weighs the violator’s compliance history and good-faith efforts. A statutory safe harbor shields good-faith, reasonable-basis Scope 3 disclosures from penalty through 2030. Penalty figures are not Master Brain values (no penalty field exists in reporting.sb_253_261.*) — stated from the statute and hand-reviewed. Source: SB-253 / SB-261 statutory text; CARB enforcement notice.

The good-faith and safe-harbor cushions

CARB’s December 2024 enforcement notice tells reporting entities that demonstrating a good-faith effort to prepare first-cycle disclosures avoids penalty for incomplete first-year reporting. Separately, the statutory Scope 3 safe harbor means that, through 2030, penalties for Scope 3 may only attach to a failure to file at all, not to good-faith misstatements made with a reasonable basis. The early years of SB-253 are therefore weighted toward getting companies reporting rather than punishing imperfect first attempts.

The SB-261 stay

SB-261’s enforcement is paused. In November 2025 the Ninth Circuit granted an injunction halting enforcement of the SB-261 deadline pending an appeal brought by business groups; the court heard oral argument in January 2026 and has not ruled. CARB has opened a voluntary docket and stated it will set an alternate SB-261 reporting date once the appeal resolves. SB-253 was not enjoined — the same court declined to halt it — which is why the emissions obligation proceeds while the risk-report obligation waits.

Common scoping errors

The recurring mistakes here are coverage and status misreadings that lead a company to wrongly conclude it is out of scope or that nothing is due. The ones below most often produce a wrong conclusion about SB-253 and SB-261.

Scope boundary — what this tool does not cover

This calculator scopes coverage under California SB-253 and SB-261 and returns the disclosures and deadlines that attach. It does not build the emissions inventory, draft the risk report, or scope the adjacent regimes — those are separate tasks, several of which have their own calculators.

The coverage determination this tool produces is the starting point: once an entity knows it is a reporting entity under SB-253, the next step is building the Scope 1, Scope 2, and Scope 3 inventory under the GHG Protocol, and drafting the SB-261 risk report if covered. The full methodological treatment of the coverage logic is on the paired California SB-253 methodology page.

Data sources and status transparency

Thresholds and cadence from the Master Brain

The revenue thresholds, the Scope 1/2 and Scope 3 first-report years, and the SB-261 biennial cadence are queryable Master Brain fields read live by the calculator engine — under reporting.sb_253_261.*, anchored to the SB-253 and SB-261 statutory text as amended by SB-219. These are outside_scopes framework-threshold records, not emission factors: the engine uses them to resolve coverage and timing, never to compute a carbon total. If the Master Brain is unavailable, the engine falls back to hardcoded values matching these rows for stale-cache safety.

Deadlines, status and penalties are hand-reviewed

The Master Brain does not carry a live deadline, status, or penalty field for these laws. It resolves the first-report years (2026, 2027), but the specific 10 August 2026 calendar deadline, the 2027 Scope 3 detail and timing, the SB-261 stay, the assurance ramp, and the penalty ceilings are stated from CARB’s own regulation and filings and the statutory text, and reviewed by hand to the date at the top of this page. Both CARB’s rulemaking and the Ninth Circuit appeal are active, so this is a fast-moving posture — confirm the current position against CARB before relying on it for a filing decision.

What the calculator deliberately does not do

The tool does not estimate emissions, draft a risk report, or file anything. It scopes coverage: revenue and California nexus in, applicable laws and deadlines out, each annotated with its current status including the SB-261 stay. The emissions inventory that SB-253 ultimately requires is built with the linked Scope 1, Scope 2, and Scope 3 calculators, under the GHG Protocol.

Versioning

The threshold and cadence parameters are read from the Master Brain (v2025.62), which stamps each result with the dataset version. The legal status and the CARB deadlines can change between Master Brain releases — a court ruling on the SB-261 appeal, a finalized Scope 3 framework, or a new CARB regulation could move them at any time. Re-confirm the status and deadlines against CARB, and re-run coverage against the current dataset, before treating any output as current. The full methodological treatment is on the paired California SB-253 methodology page.

Frequently asked questions

Methodology notes and limitations

Coverage tool, not an emissions engine. The calculator resolves coverage under SB-253 and SB-261 from total annual revenue and California nexus, and maps that coverage to the disclosures and deadlines each law carries. It does not estimate emissions, draft a risk report, or file anything. The emissions inventory SB-253 requires is built separately with the linked Scope 1, Scope 2, and Scope 3 calculators under the GHG Protocol.

Status and deadlines are stated to the review date. CARB adopted its initial regulation on 26 February 2026 (first Scope 1 and 2 deadline 10 August 2026); Scope 3 begins from 2027 with the framework in pre-rulemaking; SB-261 enforcement is stayed under a November 2025 Ninth Circuit injunction. This is a fast-moving posture — these dates and the litigation status are hand-reviewed and should be confirmed against CARB before any filing decision.

Thresholds, first-report years and cadence are read live; the calendar, status and penalties are not. The $1 billion and $500 million revenue triggers, the 2026/2027 first-report years, and the SB-261 biennial cadence are queryable fields the engine reads from the Master Brain (reporting.sb_253_261.*, outside_scopes framework markers). The Master Brain carries no calendar-day, status, or penalty field — the 10 August 2026 deadline, the SB-261 stay, the assurance ramp, and the penalty ceilings ($500,000/year SB-253, Health & Safety Code §38532; $50,000/year SB-261) are hardcoded from CARB filings and the statutory text.

Coverage turns on total revenue plus California nexus. The revenue test uses total annual revenue, not California revenue; the nexus test uses California business activity. Headquarters and incorporation location are irrelevant. CARB ties the revenue measure to the California Revenue and Taxation Code gross-receipts concept.

Scope 3 is required, and cushioned. SB-253 requires Scope 3 from 2027 — unlike the federal SEC rule. A statutory safe harbor protects good-faith, reasonable-basis Scope 3 disclosures from penalty through 2030, and CARB’s December 2024 notice grants good-faith relief for the first SB-253 cycle.

The assurance calendar is not finalised. SB-253 requires third-party assurance ramping from limited to reasonable, Scope 1 and 2 before Scope 3, but the exact calendar sits in CARB’s ongoing rulemaking. The page describes the direction of travel rather than pinning specific assurance years that CARB has not finalised.

Worked example is illustrative. The covered-retailer example shows coverage logic from revenue and nexus, not an emissions computation, because the tool scopes obligations rather than measuring emissions.

The dataset and the law both change. The Master Brain parameters are versioned; the legal status and CARB deadlines can change between releases. Re-confirm against CARB and re-run coverage against the current dataset. The full methodological treatment is on the paired California SB-253 methodology page.