California Emissions Disclosure: First Steps & Future Details
On February 26, 2026, California approved its first rules requiring large companies in the state to report Scope 1 and 2 emissions (direct emissions and purchased electricity) starting in 2026. Scope 3 (indirect emissions from supply chains) reporting begins in 2027.
EnergyTag welcomed this first step to initiate reporting, but emphasized that future rules must clarify key details, including alignment with the Greenhouse Gas Protocol (GHGP) reporting standard, as required by law.
Aligning with these global standards and ongoing updates to the GHGP Scope 2 rules will help ensure the program is effective and avoids duplicative reporting. See EnergyTag’s oral testimony to the California Air Resources Board (CARB) below:
EnergyTag Statement Delivered During Oral Testimony
“Hello Board and Staff, my name is Karl Koesser, testifying on behalf of EnergyTag. Thank you for the opportunity to comment, in addition to the detailed written testimony we have already provided.
We are an independent clean energy non-profit, and we hold positions on all three major greenhouse gas standards and target-setting bodies, and have advised US policies including California’s own Power Source Disclosure Rules set to begin in 2028.
We support the core goals of the Proposed Regulation, recognizing its focus on moving SB 253 forward and establishing reporting requirements for 2026.
We acknowledge that subsequent rulemaking is where reporting requirements will be more thoroughly developed. SB 253 calls specifically for companies to use the Greenhouse Gas Protocol Scope 2 methodology. We wish to make it clear how important it is for regulations to establish direct coordination with the updates to Greenhouse Gas Protocol Scope 2 Guidance, which are currently ongoing and expected to be finalized by the end of 2027.
Proposed revisions dramatically improve the accuracy, comparability, and decision-usefulness of corporate Scope 2 inventories, in line with the intent of SB 253. Aligning with the updated global standard will reduce duplicative reporting burden on companies and ensure the data is genuinely comparable and decision-useful.
Therefore, EnergyTag recommends that CARB commits to a rulemaking in 2028 to adopt the finalized Greenhouse Gas Protocol Scope 2 updates and ensure continued alignment between SB 253, the Greenhouse Gas Protocol, and a number of other emerging global and US standards for emissions reporting. Thank you.”
(Note: This statement was delivered orally, and while the core message remains unchanged, some wording may differ slightly from the spoken testimony. Hyperlinks have been added for context.)
