CARB's Preliminary Climate Disclosure List: What Facilities Teams Need to Know

Facilities and compliance professionals across the country have been anticipating the changes to CARB reporting, and September 2025 brought a big development.  

The California Air Resources Board recently released a preliminary list identifying approximately 2,600 companies potentially subject to SB 253 and roughly 4,100 companies that may fall under SB 261. For facilities managers at organizations that do business in California, this publication represents a concrete step toward mandatory climate reporting — and the first deadline arrives January 1, 2026.

What are the coverage thresholds for CARB?

SB 253, known as the Climate Corporate Data Accountability Act, applies to entities with annual global revenues exceeding $1 billion that conduct business in California. SB 261, the Climate-Related Financial Risk Act, sets a lower threshold than SB253:  $500 million in annual revenues. 

Both statutes, as modified by SB 219, target companies regardless of where they’re headquartered, focusing instead on their California business activities. 

CARB’s definition of “doing business in California” captures companies organized or domiciled in the state, as well as those with sales exceeding approximately $735,000 within California.  This broad interpretation means facilities teams at national retailers, restaurant chains, and multi-location operators should evaluate their exposure even if corporate headquarters sit elsewhere.

What does it mean if you’re on the list? What are its limitations?

Although many companies have been bracing for required CARB reporting, it may have still been startling to see your company’s name on the list. Exxon has gone as far as to sue California over these reporting laws, arguing that they already disclose their greenhouse gas emissions and climate-related business risks. 

Exxon argues that the goal of these reporting laws is to “embarrass” companies like theirs, and also to compel their speech to support the state’s climate goals. 

Most companies will wait to see what happens with the Exxon lawsuit while still preparing for changes. 

CARB developed its preliminary roster by cross-referencing the California Secretary of State’s business registry against revenue data from Dun & Bradstreet, applying conceptual scoping definitions discussed during recent public workshops.  However, the list carries significant limitations that facilities managers should understand before treating it as definitive.

• The entity data CARB used dates back to March 2022, making it over three years old
• The revenue information comes from what CARB describes as a “proprietary dataset,” without clear documentation of its sources or update frequency
• Technical issues further complicate matters—the California Secretary of State’s Business Search system cannot electronically search certain entity types, including LLPs, which may have affected the results
• Duplicate and inconsistent listings for single entities appear throughout the published list . 

These data quality issues explain why CARB explicitly cautions companies against relying solely on the list for compliance determinations.

Why is independent assessment still so important?  

CARB emphasizes that inclusion on the list does not constitute a final determination of reporting obligations, and it also states that absence from the list does not exempt companies from independent assessment. A lot of companies are left questioning the list and what it means for them. 

Organizations must evaluate their own applicability using current definitions and thresholds. 

Until October 27 (more than a month after the list was released), CARB accepted feedback via an online survey and encouraged listed entities to validate their inclusion or identify reasons they may qualify for exemptions—such as government entities or certain insurance companies. Companies believing they were incorrectly included needed to document their rationale for non-reporting and consider completing this survey. 

The best way to prepare for CARB reporting changes is to conduct a thorough self-assessment of your reporting obligations. 

For facilities teams, this independent assessment involves several key questions:

• Does your organization meet the revenue thresholds based on the most recently completed fiscal year?
• Is your company organized under California law, registered with the California Secretary of State, or conducting business in the state under applicable tax law?
• Do any available exemptions apply to your organization?

What are the next steps for facilities managers? 

Companies appearing on CARB’s preliminary list should consult with legal advisors to confirm statute applicability and begin disclosure preparations while monitoring CARB’s ongoing regulatory process. 

Organizations not listed but approaching the revenue thresholds should perform careful applicability analyses and document their reasoning, particularly to qualify for enforcement discretion under CARB’s stated “good faith” approach.

The publication of this list increases scrutiny from investors and other stakeholders. It has the potential to amplify compliance pressures, especially if perceived violations have the potential to cause reputational damage. 

Facilities teams at covered entities are facing heightened expectations for accurate emissions tracking, comprehensive asset data, and transparent reporting on climate-related operational risks.

CARB continues developing definitive regulatory guidance on foundational questions, including exemption qualifications and business presence determinations. Facilities managers should monitor these developments closely as the January 2026 deadline approaches.

Not sure where to start? Fexa can help. 

Fexa’s integrated platform connects facilities management with refrigerant tracking, providing the comprehensive asset data and emissions documentation necessary for both operational efficiency and regulatory compliance. Contact Fexa today to schedule a demo, where you can learn how our proven workflows can help your team meet the January 2026 deadline while building a foundation for long-term environmental reporting success.