California SB 100: Deadlines, Compliance, and Penalties

California’s SB-100 requires that 100 percent of the electricity sold to retail customers in the state come from eligible renewable and zero-carbon sources by December 31, 2045. Signed in September 2018, the law also raised the state’s Renewables Portfolio Standard from 50 percent to 60 percent by 2030 and set a series of interim deadlines along the way. A 2022 follow-up, SB 1020, added binding benchmarks for 2035 and 2040 to close the long gap between the 60 percent floor and the final target. The rules apply to every investor-owned utility, community choice aggregator, electric service provider, and publicly owned electric utility selling power in California.

The Two Tracks: RPS and the 2045 Clean-Energy Mandate

SB-100 runs on two tracks that are easy to mix up. The first is the Renewables Portfolio Standard, which requires a rising share of retail electricity to come from a defined list of RPS-eligible renewables. The second is the broader 2045 goal, which lets both RPS-eligible renewables and “zero-carbon resources” count toward the 100 percent target.¹

That split matters in practice. Reaching 60 percent renewables by 2030 is a hard procurement obligation enforced through compliance periods and penalties. The 100 percent clean-energy goal for 2045 is set as state policy under Public Utilities Code section 454.53, with the joint agencies responsible for planning the path to get there.² Both tracks apply to every entity selling electricity to California retail customers.

Interim Renewable Targets Through 2030

SB-100 rewrote the milestones utilities must hit along the way, raising each one above the prior SB-350 targets. The hard procurement floors are:

44 percent of retail sales from eligible renewables by December 31, 2024
52 percent by December 31, 2027
60 percent by December 31, 2030

The legislature also declared a goal of 50 percent renewables by December 31, 2026, which functions as a policy target rather than an enforced floor.³ After 2030, the CPUC must set ongoing three-year compliance periods requiring retail sellers to procure no less than 60 percent of retail sales from eligible renewables.⁴

The 2035 and 2040 Benchmarks Added by SB 1020

When SB-100 was signed, the law jumped from 60 percent renewables in 2030 to 100 percent clean energy in 2045 with nothing in between. The Clean Energy, Jobs, and Affordability Act of 2022 (SB 1020) amended Public Utilities Code section 454.53 to add two binding interim benchmarks for the broader clean-energy target:

90 percent of retail electricity sales from renewable and zero-carbon resources by December 31, 2035
95 percent by December 31, 2040

These targets cover the full clean-energy mix, so nuclear, large hydro, and other zero-carbon sources count alongside RPS-eligible renewables.¹ SB 1020 also extended the 100 percent clean-energy requirement to electricity procured by all state agencies.

Who Has to Comply

SB-100 reaches two groups of electricity providers. “Retail sellers” include investor-owned utilities such as Pacific Gas and Electric, Southern California Edison, and San Diego Gas and Electric, plus community choice aggregators and electric service providers. The CPUC sets their compliance periods and procurement targets.⁴

Local publicly owned electric utilities, including the Los Angeles Department of Water and Power and the Sacramento Municipal Utility District, face the same percentage targets but answer to their own governing boards, with the California Energy Commission establishing their multiyear compliance periods.⁵

One carve-out: a publicly owned utility that already draws more than 40 percent of its retail sales from large hydroelectric generation is not required to procure more than its specified minimum of RPS-eligible renewables. That exception mainly affects utilities in Northern California that rely heavily on existing hydropower.

What Counts as Eligible Energy

To count toward the 60 percent RPS target, electricity must come from certified facilities generating power from solar, wind, geothermal, biomass, biomethane, small hydroelectric (generally 30 megawatts or less), or fuel cells using qualifying renewable fuel.² Large hydroelectric dams and nuclear plants are explicitly excluded from the RPS tally.

The 100 percent clean-energy target for 2045 is broader. “Zero-carbon resources” has no formal statutory definition, but the joint agency reports have treated the category as including existing nuclear generation, large hydroelectric facilities, natural gas with 100 percent carbon capture, and clean hydrogen combustion. The flexibility is deliberate, since reaching the final 40 points between the RPS floor and 100 percent will likely require technologies that fall outside the traditional renewables list.

Who Oversees Compliance

Three state agencies share oversight of SB-100: the California Energy Commission, the California Public Utilities Commission, and the California Air Resources Board. The statute requires them to prepare a joint policy report to the legislature every four years, assessing progress and identifying obstacles.⁶ The California Independent System Operator, which runs the state’s electric grid, also contributes to those reports.⁷

Day-to-day monitoring follows the existing regulatory split. The CPUC oversees investor-owned utilities, community choice aggregators, and electric service providers through its Integrated Resource Planning and Resource Adequacy processes. The CEC oversees publicly owned utilities. Both agencies require regular reporting so shortfalls surface during a compliance period rather than at the end.

Penalties for Falling Short

The core penalty for missing an RPS procurement target is $50 per Renewable Energy Credit of shortfall, which works out to $50 per megawatt-hour.⁸ For a large utility selling millions of megawatt-hours a year, even a small percentage gap runs into the millions of dollars. Total penalties collected for non-compliance during the 2011–2013 compliance period reached roughly $4.1 million.

Fines also reach retail sellers that procure enough credits but fail to meet RPS contract and reporting requirements. In the 2017–2020 compliance period, three retail sellers in that position received revised penalties of $500 each, reflecting the administrative nature of the violation rather than an actual energy shortfall.⁸

Publicly owned utilities work under a different enforcement mechanism. Their governing boards are responsible for compliance and the CEC tracks their progress, with accountability running through public reporting rather than CPUC-imposed fines.

What SB-100 Means for Rates

As of December 2025, California’s average residential electricity rate was 34.71 cents per kilowatt-hour, more than double the national average of 17.24 cents.⁹ Not all of that gap is driven by renewable procurement; wildfire mitigation, grid infrastructure, and California’s higher construction and labor costs also feed into rates. The clean-energy buildout is one of several contributing factors.

The 2021 joint agency report estimated that moving from 60 percent renewables to 100 percent clean electricity would add roughly 6 percent to total annual electricity system costs.⁶ That number is expected to be revised in subsequent quadrennial reports as construction costs, supply chains, and demand from electric vehicles and building electrification continue to shift. The joint agencies have said cost containment, affordability, and energy equity need deeper analysis in future reports.¹⁰

1
California Legislative Information. California Public Utilities Code 454.53
2
California Energy Commission. 2021 SB 100 Report and 60 Day Report
3
California Legislative Information. California Public Utilities Code 399.11
4
California Legislative Information. California Public Utilities Code 399.15
5
California Legislative Information. California Public Utilities Code 399.30
6
California Energy Commission. SB 100 Joint Agency Report
7
California Energy Commission. Report to the Governor on Priority SB 100 Actions to Accelerate the Transition to Carbon-Free Energy
8
California Public Utilities Commission. 2025 California Renewables Portfolio Standard Annual Report
9
U.S. Energy Information Administration. Electric Power Monthly – Average Price of Electricity to Ultimate Customers by End-Use Sector
10
State of California Energy Commission. 2021 SB 100 Joint Agency Report Summary