TL;DR: If your organization is covered by SB 253, filings are due August 10, 2026. This checklist helps you confirm whether you are in scope, verify Scope 1 & 2 coverage, and tighten evidence for repeatable, audit-ready reporting.
California SB 253: Mandatory Scope 1-2 Emissions Reporting
Who is mandated to report (quick applicability check)
SB 253 generally applies to a U.S.-formed business entity (public or private) if it meets both criteria:
- Revenue threshold: >$1B in annual revenue (based on California tax concepts for gross receipts).
- “Doing business in California”: typically triggered if the entity is organized or commercially domiciled in CA, or exceeds California “doing business” thresholds (often framed as a CA sales threshold that is inflation-adjusted annually).
Note: If you are unsure whether you meet the “doing business” test—or whether reporting should be at the parent vs. subsidiary level—treat this as a short scoping exercise and document your assumptions.
Deadline: SB 253 filings are due August 10, 2026 (for covered entities, per CARB submission calendar)
What “done” looks like: a one-paragraph determination of (a) in-scope vs. not, and (b) the reporting entity/entities.
Step 1: Confirm what you already collect (30–60 minutes)
Before investing in new systems, audit your current operational data.
- Coverage: Are all relevant entities and sites included? Do you have complete coverage for all operations that roll up to the reporting entity, including recently acquired facilities or remote regions?
- Completeness: Are you collecting a full period of data? Identify any gaps by month or quarter and ensure data owners are responding consistently.
- Evidence: Can you substantiate key inputs? Ensure supporting documents (utility statements, invoices, meter reads, or vendor reports) are attached to the data points and easily traceable.
What “done” looks like: A short gap list detailing what is missing, who owns that data, and the timing for retrieval.
Step 2: Decide your path
Your strategy depends on your current data maturity.
If you already collect Scope 1 & 2 data
Focus on readiness, not reinvention:
- Tighten completeness: Eliminate missing entities, sites, or time periods.
- Tighten consistency: Standardize units of measure, naming conventions, and calculation methodologies.
- Tighten assurance readiness: Ensure your data management system captures ownership, review/approval workflows, timestamps, and a clear change history.
What “done” looks like: a repeatable collection cycle you can run again next year with minimal friction.
If you do not currently collect Scope 1 & 2 data
Establish a formal collection framework:
- Confirm which entities/sites are within the reporting boundary.
- Assign specific data owners (who provides which inputs).
- Launch your first request cycle with clear due dates and required evidence.
What “done” looks like: Scope 1 & 2 collection live in Tablecloth with owners, deadlines, and required documentation.
Step 3: Make it “assurance-ready” (light controls, high payoff)
Even if formal third-party assurance isn't required immediately, building the controls now prevents massive cleanup costs later. Standardize the following:
- Centralized Documentation: One secure location for all supporting files and links.
- Data Quality Checks: Automated or manual flags for missing months, unexpected spikes, or unit mismatches.
- Methodology Notes: Clear documentation of assumptions, estimation approaches, and boundary decisions.
- Handoff for Assurance: A clear data package that allows an auditor to test controls and request underlying source docs quickly.
What “done” looks like: You can trace any reported figure back to its source evidence in minutes, not days.
How Tablecloth Supports Your Journey
While this checklist can be executed manually, Tablecloth provides a defendable SB 253 readiness path by automating the heavy lifting. We help companies and investors with:
- Applicability + Entity Scoping: Quick confirmation and documentation of reporting boundaries.
- Gap Scanning: Instantly identifying what’s already covered vs. what’s missing in your current data.
- Workflow Deployment: Setting up a "live" Scope 1 & 2 collection environment with automated workflows and audit trails.
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