On October 12, 2026 the California Office of Administrative Law approved the California Air Resources Board’s Initial Regulation implementing SB 253 and SB 261. The rule became effective the same day. It sets November 10, 2026 as the first deadline for Scope 1 and Scope 2 greenhouse gas emissions reports under the Climate Corporate Data Accountability Act for U.S.-organized companies with more than $1 billion in annual revenue that do business in California.
CARB had earlier withdrawn the package to push the date from August 10 to November 10 and to clarify certain mechanics. The OAL approval ends that uncertainty for the 2026 cycle. More than 4,000 U.S. companies were identified in CARB’s preliminary list as likely in scope. For the first year, companies may use emissions data they already had or were collecting as of December 5, 2024, or they may file a statement of non-reporting if they were not collecting the data. Third-party assurance is not required for 2026 submissions. Scope 3 value-chain reporting begins in 2027.
SB 261, the companion Climate-Related Financial Risk Act covering companies above $500 million, remains subject to a Ninth Circuit injunction. Enforcement is stayed pending appeal. The Scope 1 and 2 obligation under SB 253 is not.
What the number actually changes for facility teams
The hard date is November 10, 2026. That is less than four weeks from the approval. Facility managers, property managers, and real-estate operators who sit inside or sell to companies above the $1 billion threshold now face a concrete data demand, not a future rulemaking.
Scope 1 covers direct emissions from company-controlled sources—on-site boilers, generators, fleet vehicles. Scope 2 covers purchased electricity, steam, heating, and cooling. Most commercial buildings generate both. The data already lives in utility bills, fuel invoices, and building-management systems. The work is assembling it into a report that matches the GHG Protocol or an equivalent standard CARB accepts.
For property managers the immediate so-what is ownership of the inventory. If the building owner or the corporate occupier is a reporting entity, someone must produce the numbers. Green-lease clauses that already allocate energy data sharing become operational this month. Facilities teams that have treated ESG language as boilerplate now have a filing date attached to it.
Contract clauses that move from aspiration to requirement
IFMA’s earlier Facility Management Pulse showed 45 percent of facilities managers already writing ESG or sustainability provisions into project contracts. The October 12 approval gives those clauses a concrete use. Price-escalation, cybersecurity, and data-security language were already rising; emissions data access is the next line item that can be justified with a calendar date.
Practical language that now has a deadline behind it includes:
- Utility and fuel data delivery within a fixed number of days after month-end.
- Access to building-management-system exports for Scope 2 calculations.
- Contractor notification of on-site fuel use or temporary equipment that creates Scope 1 emissions during a project.
- Record retention aligned with the five-year California tax-record obligation in the Initial Regulation.
None of this requires inventing new Scope 3 methodologies today. Scope 3 is still 2027. The 2026 filing is Scope 1 and 2 only. Teams that already collect vendor carbon for GRESB or internal targets can keep doing so, but the regulatory clock for purchased goods and services has not started.
Green leases and the owner-occupier split
The same building can generate reporting obligations on both sides of the lease. The owner may need Scope 2 for base-building energy. The tenant may need Scope 1 and 2 for its own operations and, later, Scope 3 Category 1 for the services it purchases. Restoration, janitorial, and capital projects sit in that Category 1 line when the tenant engages the work.
Property managers sit at the only point where every trade is authorized. Making energy and fuel data a condition of engagement is cheaper in October 2026 than reconstructing it from invoices in November. The Initial Regulation also sets an annual fee framework; earlier staff estimates put the SB 253 fee near $3,106 per entity. The fee is small relative to the cost of a late or incomplete filing, but it is real and due after the December 10 determination notice.
What to do before November 10
Confirm whether the entity is in scope: U.S.-organized, more than $1 billion revenue, doing business in California. CARB sent reminder letters to organizations on its preliminary list. If the company was not collecting Scope 1 and 2 data as of December 5, 2024, a statement of non-reporting is available for this cycle.
For everyone else, pull the utility and fuel files, map them to the GHG Protocol, and decide the submission path—CARB’s voluntary online intake platform or email to [email protected]. Document the methodology. The 2026 reports do not require limited assurance, but the data will be the baseline for later years when assurance and Scope 3 arrive.
Facility teams that treat the November 10 date as a data-collection drill rather than a compliance crisis will be positioned when Scope 3 categories that touch capital goods, purchased services, and waste begin in 2027. The OAL approval did not invent the obligation. It removed the last procedural excuse for treating it as optional.
How the 2026 numbers feed 2027 Scope 3 work
The 2026 Scope 1 and 2 inventory becomes the organizational boundary for later Scope 3 calculations. When Category 1 purchased goods and services and Category 2 capital goods enter the reporting window in 2027, the same facility data systems that produced this year’s numbers will be asked to tag contractor activity. Restoration jobs, roof replacements, HVAC retrofits, and janitorial contracts all sit in those categories when the reporting entity engages the work.
GRESB scores already reward supplier ESG monitoring. Green-lease riders that require energy and water data sharing can be extended, without new legal invention, to require the same data formats that will satisfy CARB’s 2027 templates. The Initial Regulation’s five-year record-retention rule for threshold determinations also creates a paper trail that auditors and later assurance providers will expect to see.
The practical sequence is short. First, lock the Scope 1 and 2 file by November 10 using data already in hand. Second, inventory the vendors and capital projects that will fall into Scope 3 Categories 1 and 2 next year. Third, write the data-delivery clause into the next round of service agreements so the reconstruction cost never appears. The October 12 OAL approval simply made the first step non-optional for covered entities.
Facilities operators who treat the deadline as a one-time filing exercise will spend 2027 reconstructing invoices. Those who treat it as the start of a recurring data system will have the files when the Scope 3 wave arrives. The regulation did not create new physics; it created a calendar.