California Air Resources Board

To: California Air Resources Board
Attn: SB 253 Rulemaking Comment Docket

From: GreenCircle Certified

August 27, 2025

Dear Members of the California Air Resources Board,
GreenCircle Certified respectfully submits these comments in support of a verification framework under SB 253 that endorses:

1. Verification providers accredited under ISO/IEC 17065 by ANAB (an IAF signatory); and
2. The use of the ISO 14060 series standards for limited-assurance verification.

Our recommendations align with both the statutory mandates of SB 253 and the concepts outlined during CARB’s August 21 workshop.
1. Support for ANAB-Accredited ISO/IEC 17065 Verification Bodies
Statutory Basis:
SB 253 requires that the Board adopt regulations ensuring reporting entities obtain an independent third-party assurance engagement, and that “the assurance process minimizes the need for reporting entities to engage multiple assurance providers” and ensures “sufficient assurance provider capacity.”

CARB Workshop Position:
During the August 21 workshop, CARB confirmed it “will leverage existing frameworks for accreditation of assurance providers” and will not establish its own accreditation scheme.

Comment:
We urge CARB to explicitly recognize ISO/IEC 17065 accreditation—provided by an IAF signatory such as ANAB—as satisfying the statutory requirement for assurance provider qualifications. ISO/IEC 17065 accreditation ensures impartiality, consistency, and global acceptance in certifying conformity assessment bodies. This will facilitate provider capacity, uphold independence, and align with market best practices.
2. Acceptance of ISO 14060 Series for Limited-Assurance Verification
CARB’s Acknowledgement:
CARB identified four possible assurance standards: IAASB’s ISSA 5000, AA1000, the ISO 14060 family, and AICPA auditing standards.

Statutory Timeline:
SB 253 mandates limited assurance for Scope 1 and 2 emissions initially, transitioning toward reasonable assurance—and limited assurance for Scope 3—by 2030. Board review is required by 2029 for Scope 3 assurance requirements.

Comment:
We support ISO 14064‑3 (part of the ISO 14060 series) as the appropriate standard for limited-assurance GHG verification. This international standard is specifically designed for GHG data, providing structured guidance for planning, sampling, data assessment, and reporting of limited-assurance engagements. Incorporating ISO 14060 offers transparency, consistency with global frameworks, and aligns SB 253 with existing voluntary and regulatory programs such as the GHG Protocol, CSRD, and CDP.
3. Enhancing Clarity on Assurer Qualifications and Oversight
CARB’s Guidance on Verifier Conduct:
CARB emphasized key expectations for verifiers—maintaining independence, avoiding advising and then auditing the same entity, and acting with integrity and objectivity.

Comment:
We encourage CARB to:
- Incorporate ISO 17065’s requirements for impartiality, conflict-of-interest controls, and organizational transparency.
- Reference ISO 14066, which defines competence requirements for GHG verification teams, ensuring technical rigor in assurance practice.
- Retain CARB’s authority to conduct oversight audits of assurance providers and verifications to safeguard the integrity of reported data, as contemplated in CARB’s workshop remarks.
4. Harmonization with Global Climate Disclosure Practices
CARB’s Objective of Minimizing Burden:
CARB has repeatedly stated its goal to design SB 253 with minimal burden for compliance, and indicated flexibility for good-faith reporting in early phases.

Comment:
Allowing ANAB-accredited ISO 17065 verifiers using ISO 14064‑3 aligns SB 253 with international disclosure regimes and reduces duplicative audits. It supports corporate efficiency, especially for multi-jurisdictional entities already reporting under global standards (e.g., SEC, ISSB, CSRD).

GreenCircle Certified applauds CARB’s thoughtful approach in designing SB 253’s assurance framework. By formally recognizing ANAB-accredited ISO/IEC 17065 verifiers and embracing the ISO 14060 series for limited assurance, CARB can deliver a rigorous, transparent, and globally aligned verification architecture that ensures data integrity while supporting scalable implementation.

We appreciate the opportunity to comment and are available to provide further input as CARB finalizes its regulatory provisions.

Respectfully submitted,

Sara Risley, Certification Officer
GreenCircle Certified