California’s Climate Corporate Data Accountability Act (SB 253) has been widely discussed in the context of large manufacturers and technology companies. Less discussed — but equally significant — is the exposure it creates for real estate entities. Property owners, REITs, and asset managers with California operations and revenues above the threshold face mandatory Scope 3 disclosure beginning with fiscal year 2026 data, due in 2027.
For BOMA members managing California commercial real estate, SB 253 changes the contractor relationship in a material way. The restoration contractor who responds to a water loss event at your San Francisco office tower, your Los Angeles industrial park, or your San Diego mixed-use development is generating Scope 3 Category 1 emissions that will need to appear in a mandatory public disclosure. And that contractor almost certainly has no mechanism for providing you that data today.
Who SB 253 Applies To
SB 253 applies to entities doing business in California with total annual revenues exceeding $1 billion. The law is administered by the California Air Resources Board (CARB). For Scope 3, the first reporting year is fiscal year 2026 — meaning data collection for Scope 3 needs to begin now for organizations that have not already started.
Many institutional real estate owners — national REITs, pension fund asset managers, sovereign wealth fund-backed property companies — clear the revenue threshold and have California assets. For these entities, SB 253 Scope 3 reporting is not a future consideration. It is an active compliance requirement with a defined first filing date.
The Reactive Vendor Problem for Real Estate
SB 253’s Scope 3 requirement covers all fifteen GHG Protocol categories. For property owners, Category 1 (Purchased Goods and Services) includes every contractor engaged during the reporting year — planned maintenance vendors, capital project contractors, and reactive emergency-response vendors like restoration companies.
The planned vendor relationship is manageable. You can add ESG data reporting to your master service agreements with recurring maintenance contractors, HVAC firms, and janitorial services. You can build it into your RFP process and annual vendor reviews.
Reactive vendors are the structural problem. You do not choose when a pipe bursts or when a fire damages a tenant floor. You do not run a competitive procurement when a Category 1 water loss event hits your building at 2 AM. The restoration contractor who shows up is whoever your property manager calls — and the emissions from their equipment, materials, and transportation are your Scope 3 Category 1 obligation regardless of whether they provide data or not.
The Restoration Carbon Protocol as a Compliance Bridge
The Restoration Carbon Protocol (RCP) was developed specifically to address the reactive vendor data gap. It provides restoration contractors with a standardized methodology for calculating project-level GHG emissions across equipment fuel consumption, materials, waste, and transportation — and for communicating that data to property owner clients in a format aligned with GHG Protocol Category 1 requirements.
For SB 253 compliance purposes, an RCP report from your restoration contractor provides the documented, methodology-backed data needed to populate your Scope 3 Category 1 inventory for loss events. Without it, your organization faces the CARB-specified alternative: estimation using spend-based methods — which typically overstate emissions and provide no path to reduction.
What to Put in Your Vendor Agreements Now
For California property owners preparing for SB 253 Scope 3 compliance, three vendor agreement changes directly address the restoration contractor gap. Add a GHG data delivery requirement to your preferred restoration vendor agreements, specifying RCP-compliant project emissions reports as a deliverable within 30 days of project completion. Add an ESG pre-qualification question to your emergency vendor panel selection process, asking whether candidates have adopted RCP or an equivalent methodology. And brief your property managers on the new data requirement — so that when a loss event occurs, GHG data collection is part of the project closeout process, not an afterthought six months later during annual reporting.
SB 253 enforcement has a ramp period, but the data collection requirement is retroactive to fiscal year 2026. The time to build the vendor data pipeline is now, before the loss events that will generate the data you need occur.
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