Two California laws. Two different filings. One set of underlying data.
SB 253 asks for a greenhouse gas inventory. SB 261 asks for a climate related financial risk report. They have different thresholds, different cadences and different audiences, and companies caught by both should not be running two projects to satisfy them.
Work out which one catches you before you scope the work.
The two statutes are often discussed together and are not the same obligation. The threshold is different, the deliverable is different and the reporting rhythm is different.
SB 253
A quantitative filing. Emissions across the scopes, calculated on the GHG Protocol, reported annually and subject to assurance that strengthens over time.
- Applies above the higher revenue threshold, at total annual revenues over 1 billion dollars
- Scope 1 and Scope 2 first, with Scope 3 following
- Calculated in accordance with the GHG Protocol
- Annual reporting, with assurance phased in
- The deliverable is an inventory, not a narrative
SB 261
A narrative filing, published on your own website, following the TCFD structure that IFRS S2 also builds on.
- Applies above the lower revenue threshold, at total annual revenues over 500 million dollars
- Governance, strategy, risk management, metrics and targets
- Climate related financial risk and the measures adopted to address it
- Published biennially rather than annually
- The deliverable is a report, supported by numbers
A company above the higher threshold is caught by both. The emissions inventory built for SB 253 is the same inventory that supports the metrics in the SB 261 report, provided both are drawn from one record rather than assembled twice.
Start with what you actually have to publish.
A complete climate related financial risk report, with the emissions inventory, calculations and evidence that sit behind every figure quoted in it.
- GOVGovernance of climate related financial risk, and board oversight
- STRATRisks and opportunities, resilience and scenario analysis
- RISKHow climate risk is identified, assessed and managed
- GHGScope 1, Scope 2 and Scope 3, on EPA, eGRID and IEA factors
- MEASURESThe measures adopted to reduce and adapt to the risks disclosed
One reporting process, two California deliverables.
Build the inventory SB 253 asks for.
Scope 1, Scope 2 on both location and market basis, and Scope 3 across all fifteen categories, using EPA and eGRID factors matched to the reporting year, with IEA grid factors for operations outside the United States.
Work through the risk, not just the numbers.
SB 261 asks what the climate related financial risks are and what you are doing about them. EcoLedger structures the assessment across physical and transition risk, with scenario analysis and the measures adopted recorded against each risk.
Produce both filings from the same record.
The emissions inventory and the risk report are generated from one dataset, so the figures quoted in the narrative are the figures reported in the inventory, and neither has to be reconciled to the other by hand.
Calculate. Assess. Publish.
See how one dataset produces both California filingsThe hard question is rarely the standard. It is whether you are in scope at all.
Both statutes reach companies formed elsewhere that do business in California, and both test revenue at the level of the whole entity rather than the Californian operation. That catches groups whose Californian footprint is small relative to their turnover.
The threshold is measured on total annual revenues, not on revenue earned in California, so a modest presence in the state does not put a large group outside the test.
Where a parent is in scope, subsidiaries are typically covered through the parent's consolidated reporting rather than filing on their own account.
A company can be caught by SB 261 and not by SB 253. Scoping each statute separately avoids both over reporting and a missed filing.
Scope the obligation first. The reporting work is far easier to size once you know which filings you owe.
Start with California. Extend when the perimeter does.
Because SB 261 follows the TCFD structure that IFRS S2 also builds on, the same reporting record supports climate disclosure in other markets where the group reports.
Sites, subsidiaries and group consolidation on one dataset.
eGRID subregion factors applied per site, with IEA factors outside the United States.
The same record supports the ISSB baseline where a group also reports elsewhere.
California reporting in EcoLedger.
- SB 253 emissions reporting
- SB 261 risk reporting
- TCFD reporting structure
- Scope 1, 2 and 3
- EPA and eGRID factors
- IEA grid factors
- Physical and transition risk register
- Climate scenarios
- Measures adopted, recorded
- Evidence register
- Group consolidation
- Word, PDF and HTML output
What is the difference between SB 253 and SB 261?
SB 253 requires a greenhouse gas emissions inventory, calculated in accordance with the GHG Protocol and reported annually, and applies above the higher revenue threshold. SB 261 requires a climate related financial risk report following the TCFD structure, published on your own website on a biennial cycle, and applies above the lower revenue threshold. A company above the higher threshold is caught by both.
Do the thresholds look at Californian revenue?
No. Both tests are applied to total annual revenues rather than to revenue earned in California, while the obligation itself is triggered by doing business in the state. That combination catches groups whose Californian activity is small relative to their overall turnover. Confirm your position with your advisers, since the detail sits with the regulator's rulemaking.
Which emission factors are supported?
EPA and eGRID factors across Scope 1, Scope 2 and Scope 3, matched to the reporting year rather than the current year, so prior year comparatives and restatements stay consistent. eGRID subregion factors are applied per site and IEA grid factors cover operations outside the United States.
We already report under TCFD or IFRS S2. Does that help?
Considerably. SB 261 follows the same four part structure, so existing governance, strategy, risk management and metrics narrative maps across. What usually needs attention is the specificity of the measures adopted and the evidence behind the figures quoted.
How does EcoLedger support assurance?
Each reported figure keeps its source data, calculation, factor edition and attached evidence, and a basis of preparation can be exported alongside the inventory. As assurance requirements strengthen, the evidence path an assurance provider needs already exists. EcoLedger supports your own review and assurance process. It does not provide an assurance opinion.
Tell us your revenue and your footprint. We will tell you which filings you owe.
Bring your group structure, an emissions spreadsheet or an existing TCFD report. We will map it into the EcoLedger process and show you what the two California filings and the record behind them would look like.