The California Air Resources Board (CARB) is set to adopt and put into effect the final rule for the Climate Corporate Data Accountability Act (SB 253) at the end of February 2026. The comment period on the final draft closed Feb. 9 local time. If the rule is adopted as scheduled, companies doing business in California with annual revenue of $1 billion (about 1.4 trillion won) or more must report Scope 1 and 2 greenhouse gas emissions by Aug. 10, 2026. No reference date was given for the exchange rate used in the won conversion.
As of February 2026 reporting, more than 4,000 U.S. companies fall directly under SB 253. The reporting scope widens a year later. From 2027, Scope 3 emissions including the supply chain come under the mandatory reporting requirement. The new California rules require the use of the International Sustainability Standards Board (ISSB) IFRS S2 as the reporting framework.
Another law in the same state, the Climate-Related Financial Risk Act (SB 261), is on a different track. The law requires companies with annual revenue of $500 million (about 725 billion won) or more to disclose financially material climate risks every two years. Enforcement was temporarily suspended after the U.S. Chamber of Commerce filed suit citing a First Amendment violation. A federal district court denied the petition for an injunction, and the appeal is under way at the Ninth Circuit Court of Appeals.
CARB said in a Dec. 1 statement that it would not enforce the Jan. 1 reporting deadline for SB 261. It plans to set a new reporting date once the appeal process concludes. With the two laws diverging on timing, companies covered by them now manage two different states at once, one nearing adoption and one awaiting the outcome of litigation.
The comment period results leaned toward keeping the regulation. According to an analysis by Ceres, more than half of the comments submitted to CARB supported climate risk disclosure, while 9% were clearly opposed (as of February 2026 reporting). The total number of submissions was not disclosed. Earlier, when the U.S. Securities and Exchange Commission (SEC) was reviewing its climate disclosure mandate, 310 institutional investors submitted comments in favor.
The scale on the institutional investor side is not small either. The California Public Employees' Retirement System (CalPERS), with 2.4 million members and $495 billion (about 717 trillion won) in assets under management, was one of the institutions that submitted comments in support of the SEC rule. No reference date was released along with the assets under management figure.
The European schedule also continues. The Korea Chamber of Commerce and Industry and the Ministry of Trade, Industry and Energy held the "Seminar on Changes in the EU Trade Environment and Response Strategies" on Feb. 11 at the Chamber building in Jung-gu, Seoul, reviewing together the key EU regulations taking effect, including CBAM (Carbon Border Adjustment Mechanism) and CSDDD (Corporate Sustainability Due Diligence Directive). The first session defined the EU rules as a "new trade order" and covered Korea-EU cooperation measures, and the second session dealt with the details of each system and practical response strategies. Companies operating in the EU must comply with the 2024 European Sustainability Reporting Standards (ESRS).
At the seminar, the head of the Kim & Chang ESG Research Institute said that large companies need supplier information to meet CSDDD and CSRD, which widens the actual scope of impact. The trend of requirements spreading to suppliers runs along the same line as California's schedule for widening disclosure to Scope 3 in 2027. It means companies left out of the coverage under the text of the regulations may still face demands to submit data through business relationships.
Domestic discussion continues into March. The CDP Korea Committee will hold the "2026 CDP Korea Conference" on March 10 at the Ambassador Seoul Pullman Hotel in Seoul under the theme "Climate Change and the Transition of Business, Industry and Finance." The secretariat, the Korea Sustainability Investing Forum, said it has rebranded the previously awards-centered event as a comprehensive conference from 2026. The chairman is Jang Ji-in.
The program includes a keynote address by Jose Ordonez, head of CDP Global APAC, an MoU between the Korea Sustainability Investing Forum and the Korea Accounting Institute, and the "2025 CDP Awards for Excellence in Climate Change and Water Management." The breakout sessions are organized around transition finance guidelines, real-time energy matching (Granular Certificates), the 2035 NDC and EV100.
CARB's adoption of the final rule at the end of this month, the March 10 CDP conference and the Aug. 10 Scope 1 and 2 reporting deadline fall in sequence within the year. The new reporting date for SB 261 will come only after the appeal ends. Whether the California revenue threshold refers to total revenue or in-state revenue is a matter that turns on the wording of the final rule, so this month's adopted version is the first point of confirmation.
