California has put Corporate America on notice with a preliminary roster of 4,000+ companies across apparel, beauty, payments, automotive, and luxury retail that may fall under California’s twin climate-disclosure statutes, SB 253 (greenhouse-gas emissions reporting) and SB 261 (climate-related financial-risk disclosures). At the same time, the agency stressed that the 4,000-plus-name list is non-exhaustive and non-dispositive, inclusion does not dictate coverage, and omission does not mean a company is out. 

Despite the potential ambiguities at play, the contents of the California Air Resources Board (“CARB”)’s list are significant, as the first statutory deadline arrives soon: SB 261 climate-risk reports are due January 1, 2026 (and then every two years). 

CARB has begun releasing compliance materials, including a draft Climate-Related Financial Risk Report Checklist and a process to publicly docket report links in December 2025. For SB 253, Scope 1 and 2 disclosures are targeted for June 30, 2026 (for the prior fiscal year), with Scope 3 to follow in 2027. More recently, CARB issued a proposed template for Scope 1 and 2 reporting on October 10 to streamline first-year disclosures, especially for entities new to GHG reporting. CARB also plans to release proposed regulations on October 14, opening a formal comment window.

The List & the Scope

CARB’s preliminary roster is best read as a directional tool, not a finalized list of covered entities. It sketches who might be in scope and pairs with a voluntary survey for corrections and exemptions – but each company still must perform its own applicability analysis. Derived from California Secretary of State data and revenue indicators, the list of roughly 4,150 companies should be treated as a starting point for outreach and fee-rule development, with each entity responsible for its own compliance determination.

Several limitations warrant caution. As Crowell notes, parts of the underlying entity data date to March 2022 and CARB references a proprietary revenue dataset; even CARB cautions against relying on the list to determine coverage, making independent analysis essential.

As for what types of entities are in scope …  

> For SB 253 (Climate Corporate Data Accountability Act). U.S. public or private companies doing business in California with global annual revenue > $1B must annually disclose Scope 1, 2, and (starting 2027) Scope 3 emissions for the prior fiscal year, with third-party assurance.

> For SB 261 (Climate-Related Financial Risk Act). U.S. public or private companies doing business in California with global annual revenue > $500M (excluding insurers) must publish climate-risk reports beginning January 1, 2026, and biennially thereafter.

> “Doing business in California.” CARB has floated an approach that would cover entities organized or domiciled in California or those that exceed a sales threshold in California (≈ $735,000) – a concept familiar from state tax rules. Expect further refinement in the proposed rule.

A quick scan of the list underscores its breadth, naming companies across sectors – from apparel and beauty to payments, auto, and luxury retail – including Abercrombie, adidas America, Aldo, American Express, BMW U.S., Guess, L’Oréal USA, Lucid USA, Lululemon USA, Nike, Rolls-Royce Corp. and Rolls-Royce North America, Saks Enterprise, Shiseido Americas, Skechers USA, Tapestry, The Gap, and Urban Outfitters, among others.

THE TAKEAWAY: With that context in mind, the practical takeaway is straightforward: Companies are being encouraged to treat the list as a prompt to act. “These laws bring significant compliance obligations, particularly for private companies new to mandatory climate disclosures, necessitating robust internal tracking, third-party verification, and strategic planning,” Ballard Spahr’s Lorene Boudreau recently noted.

Meanwhile, Mayer Brown added in a note of its own that “despite ongoing uncertainty, early preparation remains critical,” and that SB 253 and SB 261 place California at the forefront of climate reporting – meaning companies that align early will be best positioned to meet requirements and manage risk.