
XBRL US submitted a comment letter to the California Air Resources Board (CARB) in response to their virtual public workshop held on August 21, 2025 concerning SBs 253 and 261 for climate-related reporting. The comment letter addressed specific topics raised during the workshop:
- CARB noted that they intend to post draft reporting templates for businesses to satisfy Scope 1 and 2 reporting by the end of September. We commented that we agree with the approach to provide templates for entities not required to report GHG emissions to other regulators but urged CARB to allow companies that are already reporting sustainability data to other regulators to be able to submit the same document to satisfy California requirements to eliminate duplicate reporting. We also urged them to prepare templates they create such that they can generate structured, machine-readable data that aligns with standards used by global entities reporting to CSRD or an IFRS reporting country.
- CARB provided cost estimates for the initial implementation of $20.7 million, and $13.9 million for each year going forward. The ongoing cost will be paid through fees collected from covered entities. We suggested that a standardized data approach could reduce these charges, particularly in the years after implementation because of the economies of scale enabled through standardization, thus benefiting not only CARB but the covered entities as well.
Read: XBRL US Response to CARB Workshop August 2025
View the slides from the CARB Workshop.
Watch the recording of the CARB Workshop.