---
title: "Record Scope 3 and transition gaps against the pages that were opened"
url: "https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/map-transition-relief-and-scope-3-gaps-against-the-reporting-year-plan/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A48-A20260923-4-US"
practice_area: "Climate, ESG & Sustainability Reporting"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Record Scope 3 and transition gaps against the pages that were opened

> List what the client's papers say about scope 1, scope 2 and scope 3 emissions, and what they do not say. Do not draft a report and do not decide that a California statute applies.…

Canonical page: https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/map-transition-relief-and-scope-3-gaps-against-the-reporting-year-plan/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Climate, ESG & Sustainability Reporting](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List what the client's papers say about scope 1, scope 2 and scope 3 emissions, and what they do not say. Do not draft a report and do not decide that a California statute applies. State law governs, and the lawyer confirms the governing state. For example, California. |
| What the lawyer must review | The CARB program page says Senate Bill 253, Health and Safety Code § 38532, will require a business entity formed in California, in another state, in the District of Columbia, or under an act of Congress, with total annual revenue above one billion dollars and doing business in California, to disclose scope 1, 2 and 3 greenhouse-gas emissions annually. It says both that program and the Senate Bill 261 program are under development. Senate Bill 261, on the same page, applies to public and private U.S. companies doing business in California with annual revenue of 500 million dollars and will require biennial climate-related financial-risk reports. The page says CARB is updating a proposal to move a Scope 1 and Scope 2 reporting deadline from 10 August 2026 to 10 November 2026 if the initial regulation is approved by the Office of Administrative Law. SEC press release 2026-49 proposes to rescind the federal climate disclosure rules and records the 4 April 2024 stay. You decide whether either California program reaches the client. The tool does not write the disclosure. State law governs, and the lawyer confirms the governing state. For example, California. |
| Written for | United States |
| Applies to | [Map transition-relief and Scope 3 gaps against the reporting-year plan](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/map-transition-relief-and-scope-3-gaps-against-the-reporting-year-plan.md) |

## Checking plan

- What the AI does: List what the client's papers say about scope 1, scope 2 and scope 3 emissions, and what they do not say. Do not draft a report and do not decide that a California statute applies. State law governs, and the lawyer confirms the governing state. For example, California.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The 10 November 2026 date is a proposed deferral of Scope 1 and Scope 2 reporting, and only if the Office of Administrative Law approves the initial regulation. It is not a Scope 3 deadline.
- Doing business in California and the revenue tests are for you to apply. The page states the thresholds. It does not decide this client.
- State law governs; confirm the governing state before relying on this.

## Sources

- [California Air Resources Board, corporate greenhouse-gas reporting and climate-related financial risk](https://ww2.arb.ca.gov/our-work/programs/california-corporate-greenhouse-gas-reporting-and-climate-related-financial-risk) (checked 2026-10-22)
- [SEC press release 2026-49, proposal to rescind climate-related disclosure rules (29 May 2026)](https://www.sec.gov/newsroom/press-releases/2026-49-sec-proposes-rescission-climate-related-disclosure-rules) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*