California Air Resources Board

California Air Resources Board,

Thank you for hosting the Thursday 21 August 2025 Climate Disclosure Workshop regarding Health and Safety Code § 38533 (SB 261). Please consider the following concern.

Serco Background and Applicability

Serco is a global corporation and service provider, based in the United Kingdom (UK), consisting of multiple international divisions, including its Serco North America Division (Serco-NA). For the purposes of Health and Safety Code § 38533 (SB 261), the Serco North America Division, headquartered in Herndon, VA, functions as a subsidiary to its parent company in the UK. Serco has revenues greater than one billion dollars and does some business in the State of California. Serco is listed in the California Secretary of State Business Entity database with “Active” status. Serco-NA discloses its emissions, consolidated with other Serco Divisions at the parent-company level.

Serco emissions reporting and disclosure processes currently include Carbon Disclosure Project (CDP) Scope 1, 2 and 3 disclosure, annual Task Force on Climate-related Financial Disclosures (TCFD) reporting, third-party verification, emission reduction targets validated through Science Based Targets initiative (SBTi) and Gold Tier Canada Net-Zero Challenge participation.

Reporting Concern

Serco-NA intends to comply with California SB 261 through reports at the parent company level. Serco’s 2025 reporting period is 1 October 2024 through 30 September 2025 for TCFD and other reporting and disclosure processes outlined above. Serco’s 2025 corporate TCFD reporting will not be available until March of 2026. This is in-part due to the data gathering and information consolidation efforts for regions including North America, the United Kingdom and Europe, the Middle East and Serco’s Asia-Pacific Divisions.

The availability of Serco’s TCFD reporting in March of 2026 is beyond the required the due date of 1 January 2026 identified in SB 261. We would like to request your guidance on how Serco can provide reporting, remain in compliance, and avoid violations/fines.

Possible solutions:

Serco noted that during the 21 August 2025 CARB Workshop, other commenters raised the reporting deadlines as concerns. During the Workshop, presenters reiterated that the 1 January 2026 deadline would not likely be changed. During previous guidance and workshops, ideas included allowing reporting from the most recent available reporting year. On 1 January 2026, Serco’s most recent available reporting will be its 2024 TCFD report. Serco could post the 2024 reporting by 1 January 2026, include a message that 2025 reporting will be available in March 2026, and then update the website to also include the 2025 reporting when available in March. Another possible solution for consideration might be to keep the 1 January 2026 reporting deadline, but set a later date, a grace period, until enforcement begins. Either of these solutions will allow Serco and other companies with similar concerns to provide TCFD reporting, remain in compliance, and clearly disclose climate risks and emissions to the public within both the spirit and intent of the law.

If you wish to provide a response or guidance on our concern, please use the Serco point of contact information below.

Best regards,
Jonathan Kocher, P.E., REP, CSRP
Sr. Manager, Environment and Sustainability
Serco Inc
T: (703) 485-5367
jkocher@serco-na.com | www.serco.com