Global Sustainability & ESG Insights - November 2025

Global

COP30

Between November 10 and 22, the COP30 climate change conference took place in Belém, Brazil. Negotiations concluded with 195 Parties approving the Belém Package, which included agreements on:

• adoptation finance to triple by 2035, highlighting the need for developed countries to significantly boost climate finance for developing nations more at risk to the impacts of climate change
• establishing the Baku Adaptation Roadmap, which sets out the work for 2026–2028, until the next Global Stocktake of the Paris Agreement

• a Just Transition Mechanism to promote equity, capacity-building, and technical support
• a Gender Action Plan to strengthen support for Indigenous, Afro-descendant, and rural women

Among discussions was a notable global dialogue on the future of fossil fuels, which formed the Global Mutirão Decision. Although the final statement omitted any direct reference to fossil fuels, prompting concern from many nations, it did include strong warnings on the cost of inaction.

For further information on COP30, view our daily round-up briefings and our Strategic Reflections on COP30 webinar with the Centre for Multilateral Negotiations (CEMUNE).

ISSB to Develop Nature-Related Standards as TNFD

On November 7, the ISSB confirmed plans to introduce incremental disclosure requirements on nature-related risks and opportunities, building on IFRS S1 and S2. These requirements will draw from the Taskforce on Nature-related Financial Disclosures (TNFD) framework. The final Exposure Draft is expected by October 2026. TNFD will complete its current technical work by Q3 2026 and pause new guidance to support ISSB’s efforts. While not confirmed, ISSB’s approach may include amendments to existing standards, industry guidance, or a new standard, subject to public consultation.

Cross-Border

UK/EU: Council of the EU decision authorizing negotiations with UK on ETS agreement

On November 13, the Council of the EU authorized the European Commission to begin negotiations with the UK on potentially linking the EU and UK emissions trading systems (ETS). With the aim of avoiding carbon leakage and contributing to common sustainability goals, any future agreement would need to confirm how the linked systems would function, specify the sectors covered (including electricity, industrial heat, industry, and both domestic and international aviation and maritime transport), and create a process for adding new sectors to prevent carbon leakage and ensure fair competition. It would also allow goods from both sides to qualify for mutual exemptions under each party’s Carbon Border Adjustment Mechanism.

Asia

Singapore

Sustainable Aviation Fuel Levy Announced

On November 10, the Civil Aviation Authority of Singapore announced a new Sustainable Aviation Fuel (SAF) Levy. This Levy will take effect from October 1, 2026. It will apply to cargo shipments, and general and business aviation flights, departing Singapore, with charges varying by distance and aircraft size. Cargo shipments will be charged per kilogram, while business and general aviation flights will pay per aircraft based on wingspan categories. The Levy aims to fund SAF procurement and administration, supporting Singapore’s 1% SAF target for 2026 and its long-term goal of net-zero aviation emissions by 2050.

Europe

Regulation to simplify the Deforestation-free Products Regulation

On November 26, the European Parliament voted to simplify the Deforestation Regulation. Key changes include granting all companies an extra year to comply and simplifying due diligence requirements. If agreed, compliance timelines would be pushed back to December 30, 2026 for large operators and June 30, 2027 for micro/small enterprises. Due diligence requirements would be also streamlined, placing responsibility on those businesses which first introduce the relevant product to the EU market, as opposed to those who subsequently trade it. Micro and small primary operators will submit a one-off simplified declaration. The current text will now be negotiated between the EU Parliament and Member States before final adoption.

Amendments to the Sustainable Finance Disclosure Regulation

On November 20, the European Commission proposed amendments to the Sustainable Finance Disclosure Regulation. The proposals aim to simplify sustainability disclosures and reduce complexity for in-scope businesses. The new proposal removes some company-level reporting requirements, reduces product-level disclosures to focus on clear, comparable data. It also proposes a simple categorization system for financial products making ESG claims: Sustainable, Transition, and ESG Basics. The Commission’s proposal will now be submitted to Parliament and Council for their deliberation.

Omnibus VI: Chemical Classification Labelling Regulation Amended

On November 17, the Council of the EU approved postponing key provisions of the EU’s Classification, Labelling and Packaging of chemicals (CLP) regulation to January 1, 2028. This ‘stop-the-clock’ measure, part of the Omnibus VI simplification package, delays requirements for relabeling, formatting, advertising, and online sales, which were originally set for mid-2026 and early 2027. The move aims to reduce regulatory burdens, especially for SMEs, while maintaining safety standards. The adopted regulation will be now published in the Official Journal and enter into force 20 days later.

Omnibus I: Sustainable Reporting Requirements

On November 13, the European Parliament adopted its position on amendments to the scope of the Corporate Sustainability Due Diligence Directive and the Corporate Sustainability Reporting Directive. Under its current position, reporting would apply only to large firms with over 1,750 employees and over €450 million net annual turnover, with fewer qualitative details required to be submitted. Sector-specific reporting would become a voluntary process. Due diligence duties would cover very large corporations to include those with over 5,000 employees and an annual net turnover of more than €1.5 billion, using a risk-based approach and relying on existing data. Transition plans would no longer be required, and liability would be at national level. Institutional negotiations are expected to take place and remains unclear if further amendments will be set out.

EU Climate Law Amendment

On November 13, the European Parliament adopted its position on amending the EU Climate Law. The amendment sets out a binding target to cut net GHG emissions by 90% by 2040, compared to 1990 levels. From 2036, up to five percentage points of reductions could come from high-quality international carbon credits, subject to strict safeguards following concerns from the European Commission. MEPs also backed postponing ETS2, covering CO₂ emissions from buildings and road transport, by one year to 2028. This target is set to be reviewed biennially. The European Parliament will now begin negotiations with Member States on the final law.

Legislative Package on One Substance, One Assessment Adopted

On November 13, the Council of the EU adopted the ‘One Substance, One Assessment’ (OSOA) legislative package to streamline chemical safety evaluations across the EU. The new rules aim to speed up regulatory action on chemical risks, improving health and leading to better and faster environmental protection. OSOA also aims to enhance consistency and efficiency in assessments for sectors such as food, toys, pesticides and medical devices. It introduces a common data platform, integrating information from over 70 EU laws and including a database of safer alternatives. The package also clarifies EU agency responsibilities and strengthens institutional cooperation. The adopted acts will be now published in the Official Journal and enter into force 20 days later.

Revision of the New Legislative Framework

On November 12, the European Commission opened a consultation on revising the New Legislative Framework (NFL). The NFL underpins EU product safety rules, CE marking, and market access. The proposed changes aim to simplify requirements, reduce administrative burdens, and improve coherence across sectors, ensuring products remain safe and compliant while supporting sustainability and fair competition. Potential changes include introducing a digital product passport, aiming to support the EU’s circular economy objectives.

Sustainability Reporting Standards Postponed

On November 10, the Quick Fix Delegated Regulation was published, providing targeted relief postponing certain sustainability reporting requirements under the European Sustainability Reporting Standards (ESRS) framework. This Regulation provides reporting relief to first wave businesses subject to ESRS, allowing businesses to omit certain disclosures, such as anticipated financial effects of sustainability risks until FY2027. Also, businesses with 750 employees or more will also benefit from the same phase-in provisions that apply to businesses with 750 employees or less.

Taxonomy Delegated Acts

On November 7, the European Commission launched calls for evidence on proposed amendments to the Taxonomy Climate Act and the Environmental Delegated Act. These Acts set technical screening criteria for activities aligned with six EU environmental objectives. The planned changes aim to improve clarity, usability, and legal certainty by simplifying criteria and reducing complexity. Feedback will inform targeted revisions to enhance cost-effectiveness and coherence of the EU Taxonomy framework. The feedback period closed on December 5.

UK

Autumn Budget Announcement

On November 26, the Government announced their Autumn Budget. As part of the budget, the Government put forward a range of sustainability-related measures. The key announcements include:

• capital infrastructure will be invested in to support, among other things, greater energy security across the country, with additional investment being announced for “major growth projects”
• confirmation the Carbon Border Adjustment Mechanism (CBAM) would be introduced under the Finance Bill 2025-2026. Indirect emissions within scope of CBAM will be delayed until 2029. The Government is considering including refined products in CBAM in future
• confirmation the standard and lower rates of landfill tax would not be merged into a single rate
• confirmation the UK Plastic Packaging Tax (PPT) rate for 2026 to 2027 will increase in line with CPI inflation
• confirmation a consultation would be launched on the introduction of mandatory certification for mechanically recycled plastic packaging for businesses to claim an exemption from PPT

Planning and Infrastructure Bill

On November 24, the Planning and Infrastructure Bill cleared the House of Lords. The Bill has now returned to the House of Commons, where it will consider the amendments made. Key amendments made by the House of Lords include:

• enhanced protections for chalk streams
• prioritisation to redevelop of brownfield sites
• proposal that the Government publish an assessment of the impact of existing regulations on low-hazard reservoirs and, within six months of the Bill’s enactment, set out proposals for their deregulation

The Bill is sat with the House of Commons, who will review the amendments on December 8.

Employment Rights Bill

On November 15, the House of Commons rejected several House of Lords’ amendments to the Employment Rights Bill. The Bill now returns to the House of Lords to review the government’s stated reasons for rejecting the amendments. These include:

• protection from unfair dismissal should apply from the first day of employment
• workers who meet the qualifying criteria should automatically receive a guaranteed hours offer, rather than having to request one
• the requirement that industrial action is only valid if at least 50% of eligible voters participate in the ballot should be removed

For more information, please see our Preparing UK employers for workplace changes tracker.

FRC issues ISSA (UK) 5000

On November 12, the Financial Reporting Council (FRC) issued International Standard on Sustainability Assurance (ISSA) (UK) 5000, “General Requirements for Sustainability Assurance Engagements”, providing UK companies, investors and assurance providers with internationally aligned voluntary assurance standards. This UK adaptation of the global IAASB standard provides requirements for both limited and reasonable assurance engagements. Designed for voluntary use, it aims to enhance the credibility of sustainability reporting, support informed investment decisions. The standard reflects FRC’s commitment to internationally aligned frameworks, promoting consistent assurance practices and reliable information for investors.

Draft Amendment to the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025

On November 3, draft regulations amending the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2025 were published. The changes, effective from January 1, 2026, allow deductions for recycled food-grade plastics collected in closed-loop systems, and clarify producer obligations. The amendments aim to close loopholes and simplify compliance for in-scope businesses.

US

Endangered Species Act Regulations

On November 19, 2025, the US Fish and Wildlife Service proposed four rules under the Endangered Species Act regulations, to require economic impacts to play a greater role in listing decisions and critical habitat designations, narrow the effects that must be considered under Section 7 consultation, and to remove the “blanket rule” that applied the same protections for “threatened” species as those that apply to “endangered” species.

Waters of the United States Rule

On November 17, 2025, the EPA and US Army Corps of Engineers issued a proposed rule to revise the definition of “waters of the United States” (WOTUS) under the Clean Water Act. The stated purpose of the rule is to conform the definition with the US Supreme Court’s decision Sackett v. EPA.  Among other things, the proposed rule provides jurisdiction over only tributaries connection to traditional navigable waters, provides definitions for “continuous surface connection” and “relatively permanent,” eliminates “interstate waters” from the definition of WOTUS,  and revises exclusions for ditches, waste treatment systems, prior converted cropland, and groundwater. 

EPA Proposes Amendments to PFAS Reporting

On November 11, 2025 the Environmental Protection Agency (EPA) announced plans to amend requirements for businesses to report PFAS use under the Toxic Substances Control Act. The original rule, finalized in 2023, mandated reporting on PFAS usage between 2011 and 2022, related to exposure and any existing environmental and health effects. The proposal introduces exemptions for PFAS in concentrations of 0.1% or lower, imported articles, certain byproducts, impurities, research chemicals, and non-isolated intermediates. Public comments on the revisions will be accepted for 45 days before final rules are issued.

Further reading and listening

FRC Review of Corporate Governance Reporting 2025

COP 30 Insights

Strategic Reflections on COP30 webinar with the Centre for Multilateral Negotiations (CEMUNE)

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