Horizon – News and Trends in Sustainability Law

Deadline alert

• European Union: The application deadline for large companies under the EU Deforestation Regulation (EUDR) is December 30, 2025.


• California: Under SB 261, the Climate-Related Financial Risk Act, covered entities are required to post their first biennial climate-related financial risk report to the California Air Resources Board (CARB) public docket by January 1, 2026. However, as we discuss below, the Ninth Circuit has currently enjoined the state from enforcing this rule pending the outcome of Chamber of Commerce of the United States of America et al. v. California Air Resources Board. For SB 253, the Climate Corporate Data Accountability Act, August 10, 2026 has been proposed as the initial deadline for Scope 1 and 2 reporting.


• Australia: Group 1 companies must comply with the new Australian sustainability reporting rules in their FY2025 annual reports, which for most are due in Q1 2026.
  
  

Please also see our sustainability calendar for information about key reporting deadlines around the world.

Inside COP30

The 30th United Nations Climate Change Conference (COP30) took place from November 10 to 21 in Belém, Brazil.

The US maintained a presence through a large coalition of 100 state and local leaders and US-based nonprofits, led in part by the US Climate Alliance. Notable US attendees included California Governor Gavin Newsom, New Mexico Governor Michelle Lujan Grisham, Wisconsin Governor Tony Evers, former Vice President Al Gore, and the mayors of several major cities, such as Annapolis, Maryland; Austin, Texas; Phoenix, Arizona; and Savannah, Georgia. United States Senator Sheldon Whitehouse (D-RI), credentialed as part of the delegation of the Sustainable Energy and Environment Coalition Institute, also attended.

Here are some of the notable decisions made during COP30:

• The participating countries adopted the Belém Political Package, anchored by the Global Mutirão decision, which pivots the multilateral climate regime from target setting to implementation through a new Global Implementation Accelerator.


• The parties further adopted the Belém Mission to 1.5, led by the troika of the most recent COP Presidencies (the United Arab Emirates, Azerbaijan, and Brazil); a finance track that includes a ministerial review of the new Collective Quantified Goal; and a call to at least triple adaptation finance by 2035.


• Negotiators finalized the architecture of the global goal on adaptation with a voluntary suite of 59 indicators. They also launched the Belém–Addis process to operationalize the indicators, while agreeing to develop a just transition mechanism under the UAE work program through a decision to be made at COP31.


• On carbon markets, countries extended to June 2026 the deadline to transition the Kyoto Protocol’s Clean Development Mechanism (CDM) activities to the Paris Article 6.4 mechanism for privately traded emission reductions and approved a transfer of CDM resources to bridge near term funding. They additionally released guidance to strengthen reviews under Article 6.2 for country-traded reduction outcomes and improve the non market approaches platform under Article 6.8.


• Efforts to align finance flows with a pathway toward low greenhouse gas emissions and climate-resilient development under Article 2.1(c) will continue via the three year Veredas Dialogue and high level Xingu Finance Talks, with safeguards underscoring nationally determined, non punitive approaches.


• Countries welcomed new pledges to the Fund for Responding to Loss and Damage, confirmed direct-access modalities for all developing countries, and established a replenishment cycle for the Fund.


• Looking ahead, Australia and Turkey will co host COP31 in November 2026 in Antalya, with the Pacific Islands hosting the Pre COP.

Businesses may wish to consider monitoring evolving finance alignment expectations, Article 6 integrity and reporting requirements, and an emerging “just transitions framework” that will shape investment flows and disclosure priorities through the next five-year cycle of nationally determined climate commitments.

Disclosures and voluntary reporting

CARB workshop and updated FAQs: Implementation cadence, scoping, and first year expectations. Although the order from the Court of Appeals for the Ninth Circuit enjoining enforcement of SB 261 casts doubt on the future of California’s climate disclosure laws, CARB’s November 18 workshop, alongside the November 17 update to its FAQs, provides clarity for initial compliance under those laws if implemented as planned. For SB 253, CARB continues to target a first year Scope 1–2 reporting deadline of August 10, 2026, with a pragmatic “provide what you have” approach for 2026 that permits submission of existing emissions information (including data reported under other programs) and limited assurance obligations commencing with 2026 reporting but tempered by first year enforcement discretion. Applicability of the laws pivots on two anchor definitions: “revenue” will track Franchise Tax Board “gross receipts,” determined using the lesser of the two most recent fiscal years, and “doing business in California” will be based on Revenue & Taxation Code section 23101, with CARB proposing exclusions for entities whose only California activity is teleworking employees, nonprofits, government and majority owned affiliates, and insurers. Parent–subsidiary structure remains central to reporting mechanics, and coverage is assessed at the entity level, although consolidated reporting is permitted where corporate association criteria are met. Fees will be assessed per covered entity, though a parent may remit a combined payment. Together, these materials signal CARB’s intent to align with familiar tax and disclosure concepts while phasing in obligations to ease first year compliance. CARB has also updated its climate-related financial risk disclosure checklist and FAQs.

ISSB announces work on nature-related reporting standards for investors. Responding to calls from investors, the International Financial Reporting Standards (IFRS) Foundation’s International Sustainability Standards Board (ISSB) has announced it is working on a new initiative to set standards for disclosure requirements on nature-related risks and opportunities. The initiative, ISSB stated, would be based on the Taskforce on Nature-related Financial Disclosures (TNFD) framework, which was developed to help businesses and financial services entities integrate nature into their decision-making through reporting on their nature-related dependencies, impacts, risks, and opportunities. In April, TNFD and the IFRS Foundation announced they had signed a memorandum of understanding formalizing their collaboration on nature-related financial disclosures for capital markets. This month, in the wake of the ISSB announcement about the new initiative, TNFD announced it is pausing its work on new technical guidance beyond that currently in progress, instead concentrating on supporting the ISSB’s work program. At this early stage, the ISSB is reportedly still determining the form of the new standard – such as whether it would be a stand-alone standard or an amendment to current criteria. The ISSB intends to release an initial draft of the new standards by October 2026, just ahead of the 17th Convention on Biological Diversity.

SBTi seeks feedback on updates to Corporate Net-Zero Standard V2. December 8 is the last day to provide feedback to the Science Based Targets initiative (SBTi) on its latest proposed updates to the Corporate Net-Zero Standard V2. The goal of the updates is to offer businesses a more streamlined, flexible reporting structure, that, SBTi states, “brings together scientific integrity and practical application, making net-zero target setting easier to understand, apply, and scale” for a diverse range of companies. Among the overarching changes is a new approach to targets that is tailored to specific scopes “to better reflect the unique challenges and decarbonization levers companies have in different contexts, allowing them to focus on priority emissions sources where they can have the most impact.” The draft also features a new recognition mechanism for certain companies that voluntarily assume responsibility for their ongoing emissions, as well as a new requirement for all Category A companies to progressively assume responsibility for such emissions starting in 2035. Also new in this draft is a requirement for companies to report on the barriers they are facing in striving for their emissions targets – a requirement SBTi is adding to help reporting entities stay the course while showing that their climate strategies are robust and accountable. Read the draft SBTi Corporate Net-Zero Standard Version 2.0 here, and see SBTi’s explanatory document about it here.

GHG Protocol announces public consultation on revisions to Scope 2 reporting standards. In late October, the Greenhouse Gas Protocol (GHG Protocol) launched a public consultation seeking views on proposed updates to its reporting standards for Scope 2 emissions, the indirect GHG emissions from purchased electricity, steam, heat, or cooling. The revisions are significant for power generators, electricity suppliers, and major energy users that voluntarily align their emissions reporting with the GHG Protocol standards, as well as those that use the standards for mandatory reporting under laws like the Corporate Sustainability Due Diligence Directive (CSDDD). In particular, the revisions aim to refine the Location-Based Method’s emission factor hierarchy and strengthen the Market-Based Method, which would particularly impact producers of renewable energy. The consultation is open until December 19.

Greenwashing

Three trends in US greenwashing litigation. In recent weeks, newly filed greenwashing cases in the US have reflected one of three themes. First, in California, more plaintiffs are invoking consumer protection statutes to challenge recyclability claims under the state’s recently adopted standards on recyclability. For instance, Dimino v. Food 4 Less of California Inc., a putative class action filed on October 24, charges that the grocery retailer falsely marketed products as “100% recyclable” but that those products do not meet state recyclability thresholds. The lawsuit also alleges that Food 4 Less charged customers for the California redemption value fees on ineligible products. A second theme involves ingredient and composition representations, long a high risk area for consumer products. One example is Erin Welsh v. Credo Foods, PBC, a putative class action filed in the Circuit Court of the City of St. Louis on November 5. The plaintiff is challenging a manufacturer’s claims that two of its vegan pasta sauces are plant-based when the sauces contain a synthetic ingredient, xanthan gum. Third, climate related fee and offset representations are an emerging vector, as found in Fischer v. Laird Superfood, Inc., filed in the US District Court for the Central District of California on October 25. Fischer alleges the company required carbon offset and shipping protection fees for online orders without obtaining customer consent. This case signals closer attention to how brands operationalize offset programs, charge consumers, and communicate climate benefits.

E-cigarette maker to seek dismissal of putative class action over “carbon neutral” claims. In another example of greenwashing litigation over climate related fee and offset representations, R.J. Reynolds Vapor Co. and its affiliates (RJR) will ask the US District Court for the Northern District of California to dismiss a putative class action case alleging that advertising Vuse e-cigarettes as “carbon-neutral” violates California's unfair competition law and Federal Trade Commission standards on environmental marketing claims. The plaintiffs, three e-cigarette consumers, stated in their original complaint that Vuse e-cigarettes have been marketed since 2021 as “the first ever global carbon-neutral vape products,” and that their use would result “in no net addition of CO2 to the atmosphere." The plaintiffs call it “greenwashing,” adding that they “paid for vaporizers and vape products marketed as environmentally superior, but received products whose environmental claims rely on ineffective and redundant offset projects that fail to provide genuine carbon reductions.” RJR responded that its carbon-reduction efforts were genuine and transparent and have been certified as carbon neutral by an independent third party, Vertis. The plaintiffs’ distaste for that certification, RJR said, “does not make Defendants' statements false or misleading.” The defendants filed a Notice of Motion to move for dismissal at the next case hearing on February 3, 2026.

Canada: Government proposes updating greenwashing provisions in the Competition Act. In June 2024, Bill C-59 made significant amendments to Canada’s federal Competition Act. Certain new provisions targeted greenwashing, creating reverse-onus requirements that businesses must prove that any:

• claims of a product’s environmental benefits (including with respect to climate change) be based on an “adequate and proper test” [para. 74.01(1)(b.1)] and


• claims of the environmental benefits of a business or business activity (including with respect to climate change) be based on “adequate and proper substantiation in accordance with internationally recognized methodology” [para. 74.01(1)(b.2)].

Many constituents in the business community expressed concerns with the breadth and uncertainty of these provisions. Bill C-59 also expanded the right of private parties (which could include interest groups and competitors) to apply to the Competition Tribunal for permission to enforce various civil provisions of the Act, including deceptive marketing practices (which in turn include the new greenwashing provisions).

On November 4, the recently re-elected Liberal government, now under Prime Minister Mark Carney, tabled Federal Budget 2025, in which it announced legislative changes to “support investment certainty and the adoption of energy efficient goods.” As part of this, the government proposed to “update” the greenwashing provisions by removing the requirement for businesses to substantiate their environmental benefit claims based on internationally recognized methodology standards and the ability for third parties to bring cases directly to the Competition Tribunal for greenwashing complaints. The government acknowledged that the uncertainty of the “greenwashing” provisions was having “the opposite of the desired effect with some parties slowing or reversing efforts to protect the environment.”

The government has since tabled budget implementation legislation. The implementation bill proposes narrow changes, leaving most of the new provisions intact. The bill would remove the words “in accordance with internationally recognized standards” in para. 74.01(1)(b.2) to describe the type of substantiation that is required. The implementation bill proposes to remove the ability of private parties to seek leave to enforce para. 74.01(1)(b.2). This change would not prevent private parties from seeking to enforce para. 74.01(1(b.1) – that is, applications in respect of environmental claims about products – or the more general provisions dealing with false or misleading presentations to the public, which are broad enough to cover environmental claims.

Sustainability: Regulatory

State AGs voice concern over recycling practices. On October 29, attorneys general (AGs) from multiple US states, among them Florida and Texas, sent letters to environmental groups regarding antitrust concerns over coordinated recycling practices. Florida AG James Uthmeier, who leads the coalition, wrote that certain groups “are hindering states’ economic prosperity by coordinating business behavior, which would constitute violations of Florida’s antitrust laws.” The state AGs allege the groups pushed corporations to use the same plastic production and packaging standards, which they allege could limit competition and, thus, lead to higher costs and fewer consumer choices.

Implementation of New York’s All-Electric Buildings Act is suspended. In a stipulation filed in the US District Court for the Northern District of New York on November 12, the State of New York has agreed to indefinitely suspend implementation of the All-Electric Buildings Act (AEBA) while a federal court appeal over the act plays out. AEBA’s purpose, part of a broader effort to address emissions from New York’s building sector, is to help the state reach its net-zero goals by banning equipment and infrastructure that burns fossil fuels in new construction and requiring most new buildings to install efficient electric appliances, such as heat pumps. The first phase of AEBA was to go in effect on January 1, 2026, affecting new-construction residential buildings below eight stories and commercial and industrial buildings with a footprint of up to 100,000 square feet. The second phase, starting January 1, 2029, extends the requirements to most remaining categories of new construction. The suspension is an about-face for the Hochul administration, which on October 1 had filed a brief with the district court stating that New Yorkers would “suffer irreparable harm if the Code amendments are delayed from taking effect.” On November 13, Ken Lovett, the governor’s senior communications advisor on energy and environment, stated, "The governor remains committed to the all-electric-buildings law and believes this action will help the state defend it.” Because oral arguments on the litigation in the US Court of Appeals for the Second Circuit have not yet been scheduled, it is likely that the earliest this case could be resolved, and the regulatory suspension potentially lifted, is fall 2026.

Sustainability: Litigation

Ninth Circuit stays enforcement of California SB 261 pending appeal. On November 18, the US Court of Appeals for the Ninth Circuit issued an injunction staying enforcement of California’s SB 261, the Climate-Related Financial Risk Act, pending the outcome of Chamber of Commerce of the United States of America et al. v. California Air Resources Board. The court, however, declined to enjoin SB 253, the Climate Corporate Data Accountability Act. This injunction adds an extra layer of uncertainty. Covered entities are not required to submit their SB 261 reports on January 1, 2026, while the injunction is in place. On the other hand, SB 253 remains in effect, and California may continue its implementation activities.

Following the Ninth Circuit's decision, the parties will meet and confer and, within 21 days, file a proposed case management order setting renewed deadlines for discovery, pre-trial motions, and trial.

Earlier this month, the plaintiffs in Chamber of Commerce v. CARB called on the US Supreme Court, via an Emergency Application for Injunction Pending Appeal to the United States Court of Appeals for the Ninth Circuit, to block the enforcement of SBs 253 and 261. The Ninth Circuit’s ruling forestalls Supreme Court review, at least for now. See our earlier coverage of this litigation here.

Northern District of New York asked to permanently enjoin enforcement of New York Climate Change Superfund Act. On October 31, the plaintiffs in West Virginia et al v. Letitia James, one of the two lawsuits aiming to strike down New York’s Climate Change Superfund Act, asked the US District Court for the Northern District of New York to permanently enjoin New York from enforcing it. The Act, signed into law by Governor Kathy Hochul in December 2024, requires companies that are collectively responsible for the largest proportions of historical global GHG emissions to pay the state approximately USD75 billion across 25 annual payments. The lawsuit was brought in February this year by 22 AGs from Republican-led states. It describes the New York law as an “extraterritorial shakedown,” asserting that it is unconstitutional and preempted by the Clean Air Act. New York’s Climate Change Superfund Act faces a related challenge from the federal government in USA and EPA v. New York. Vermont’s Climate Superfund Act, the nation’s first, is also being challenged by the Trump Administration and a coalition of businesses and AGs. See some of our earlier coverage of these actions here and here.

NYSDEC ordered to comply with Climate Leadership Act by February 6. In a landmark decision handed down late last month, the Albany County Supreme Court ruled that New York’s Department of Environmental Conservation (NYSDEC) violated the law by failing to issue binding regulations under the state’s Climate Leadership and Community Protection Act (CLCPA). The CLCPA, enacted in 2019, requires a statewide cut in GHG emissions by 40 percent by 2030 and 85 percent by 2050, compared to 1990 levels. To achieve that, the act directs NYSDEC to develop and issue promulgating regulations, including to convert the cap-and-trade program to cap-and-invest program. Those regulations, under the CLCPA, were to have been finalized by January 1, 2024. In January 2025, the agency announced that the draft regulations would not be released this year. In March, a coalition of environmental groups sued to make the state comply. See Citizen Action of New York, et al v. New York State Department of Environmental Conservation. On October 24, the Albany County Supreme Court ordered the NYSDEC to promulgate the regulations no later than February 6, 2026. Noting that the agency lacked discretion to delay its compliance, the court concluded, “It is undoubtedly true that the task placed before the DEC is very complicated indeed. But as a legal argument, this is unavailing.”

Supply chain integrity

New American National Standard for traceability of solar supply chains. The American National Standards Institute recently announced that it has officially approved a new American National Standard, ANSI/SEIA 101, setting out traceability requirements for identifying the source of a product’s material inputs and tracing their movement through the supply chain. Developed by the Solar Energy Industries Association (SEIA), the new standard was driven by US Customs requirements for the traceability of solar supply chains arising from the Uyghur Forced Labor Prevention Act (UFLPA). Enacted in 2021, the UFLPA aims to “ensure that goods made with forced labor in the Xinjiang Uyghur Autonomous Region [XUAR] of the People’s Republic of China do not enter the United States market.” It creates a rebuttable presumption that goods with any input from the Xinjiang Region in the People’s Republic of China or made by certain entities were manufactured in part or wholly by forced labor and therefore are prohibited from entry into the US. To overcome the rebuttable presumption and receive an exception from CBP, importers must meet a high evidentiary standard in demonstrating that the goods were not made with forced labor, among other requirements. SEIA claims that it based ANSI/SEIA 101 on real-world examples of solar product shipments that had been detained and released by Customs officials, with input from such stakeholders as manufacturers, developers, and third-party auditors. Compliance with the new standard does not guarantee compliance with the UFLPA, nor does it immunize a company from regulatory action, but standards such as ANSI/SEIA 101 provide a best-practice reference and a helpful tool to improve supply chain traceability. See ANSI/SEIA 101 here.

EU: Omnibus I in the news. The EU continues to advance Omnibus I, the set of proposed simplification measures that will streamline key reporting and compliance requirements of the bloc’s Green Deal: the Corporate Sustainability Reporting Directive (CSRD), CSDDD, EU Green Taxonomy, and Carbon Border Adjustment Mechanism (CBAM), while exploring the possibility of postponing, yet again, enforcement of the EU Deforestation Regulation (EUDR). Here are the latest developments:

• Deadlock over EUDR reforms. At this writing, the EUDR is still set to come into force on December 30, but European lawmakers are currently debating three separate reform proposals that would each delay its implementation. The latest proposal from the Danish presidency features a blanket one-year delay for all businesses: large and medium-sized entities’ reporting would be delayed by a year, to December 30, 2026, and compliance for small and micro enterprises would kick in on June 30, 2027. In late September, EU Environment Commissioner Jessika Roswall recommended a one-year reporting delay for large and medium-sized entities, pointing to concerns about the readiness of the Commission’s IT systems. Then in October, the European Commission recommended preserving the current reporting dates for large and medium-sized enterprises while exempting downstream entities from submitting due diligence statements. Reportedly, Member States overall agreed on delaying EUDR compliance deadlines but were unable to reach a consensus on such factors as traceability requirements and the possible addition of a so-called review clause, which would allow them to revisit and possibly further alter the EUDR in one year.


• European Parliament arrives at its negotiating position on CSDDD and CSRD. On November 12, the European Parliament voted, 382–249, on its negotiating position regarding reforms to the CSDDD and CSRD. The position would put in place substantive changes to the two directives – dramatically reducing the number of companies covered by the CSRD an estimated 92 percent by setting a new threshold of 1,750 employees and EUR450 million in revenues, and also slashing the scope of the CSDDD to cover only the largest companies, with a threshold of 5,000 employees and revenues of over EUR1.5 billion. Companies below the scope would be shielded from requests for information greater than that set out in voluntary sustainability reporting standards. Additionally, entities still in scope of the CSDDD would be directed to rely on information that is already available, rather than requesting information from smaller companies lower in the value chain, and to request information from smaller business partners solely as a last resort. The reforms would also forbid companies reporting under the CSRD to request information from out-of-scope companies beyond the requirements of voluntary standards. Further, the parliamentary position would delete the requirement for companies to prepare a net-zero transition plan. Policing of failures to comply with due diligence requirements would shift from the EU to the Member States. Trilogue negotiations among the Parliament, Council, and Commission on the CSDDD and CSRD reforms began on November 18.


• Parliament’s vote comes as pressure is mounting on the EU to modify or even abandon the CSDDD and CSRD. For instance, in early November, a multi-state coalition of state AGs from Republican-led states, helmed by James Uthmeier of Florida, wrote to the heads of several major US-based companies pressing them to refuse to comply with the CSRD and CSDDD’s requirements. The letters voice the AGs’ “collective concern” about the sustainability regulations and state that compliance with the two directives “is unlawful in the United States.” On October 29, the largest US business associations wrote to members of the White House Cabinet about the “egregious mandates” in the CSDDD and CSRD, particularly objecting to the directives’ extraterritorial aspects, which apply to companies doing business in the EU wherever they are based. “If CSDDD proceeds with extraterritorial subjugation intact, American businesses could be forced to respond to protect their interests,” the letter stated. The letter was sent to Treasury Secretary Scott Bessent, US Trade Representative Jamieson Greer, White House National Economic Council Director Kevin Hassett, and Energy Secretary Chris Wright. And, speaking on November 3 during the 2025 Abu Dhabi International Petroleum Exhibition and Conference, Qatari Minister of State for Energy Affairs Saad Sherida Al-Kaabi reiterated Qatar’s opposition to the CSDDD and CSRD, stating that, if Europe “does not look at how to water down” or cancel the two directives, “we will not be delivering LNG (liquefied natural gas], for sure 100%,” to the bloc.
  

Energy and natural resources

Businesses, legislators push back on EPA plans to end GHGRP. The Environmental Protection Agency (EPA)’s proposal to eliminate the Greenhouse Gas Reporting Program (GHGRP), announced in September, has reportedly received significant pushback from both businesses and bipartisan legislators. The proposed rule would end emissions reporting requirements that have been in place since 2010 for about 8,000 US facilities, such as steel mills, oil refineries, and coal-burning power plants. Among those who have publicly objected to the change are the American Petroleum Institute (API), which on November 3 set out its objections in a 21-page submission to EPA asserting that the GHGRP’s “multiple benefits outweigh the costs.” Among the benefits API cites: GHGRP reporting provides “a unique dataset that serves a multitude of valuable purposes beyond regulatory compliance” and underpins tax credits that incentivize US oil and natural gas development. Further, in an era in which importers around the world need to comply with multinational rules, “halting or suspending the GHGRP risks putting U.S. natural gas and crude oil exports at a competitive disadvantage” in the global marketplace. In addition, also on November 3, a bipartisan group of federal legislators, led by Senators Kevin Cramer (R-ND) and Sheldon Whitehouse (D-RI), submitted comments to EPA stating that the GHGRP is beneficial for American industry. They state, “EPA projects that discontinuing the GHGRP will provide between USD2 billion and USD2.4 billion in cost savings over the next ten years. This amount is far outweighed by the capital jeopardized by EPA’s action including but not limited to the $77.5 billion invested in existing and near-term CCUS projects, the $30 billion in tax revenues to American industry under 45Q before OBBBA, with billions more expected after OBBBA, and the billions of cubic feet of LNG, valued at over 2 billion dollars per day, exported from the United States.” Other leading business groups, such as the National Association of Manufacturers and the Business Roundtable, also provided comments opposing elimination of the GHRGP. The comment period on the proposed rule closed on November 3.

Interior Department acts to expand oil and gas leasing. On November 10, the Washington Post reported on plans by the Interior Department to expand oil and gas leases in broad offshore swaths of California and Alaska and in the eastern Gulf of Mexico. The Alaska portion of the plan would affect nearly all its offshore areas, including the remote, pristine High Arctic. The proposed expansion would supplement dozens of offshore oil lease auctions that have already been approved under the 2025 budget legislation. According to the Post, final approval of the draft proposal would take at least a year, and production would not begin for several more years. Expanding such development in the eastern Gulf of Mexico would require the Administration to reverse the moratorium President Donald Trump placed on such leases during his first term. Then, on November 13, the Interior Department announced a final rule that rescinds a 2024 rule limiting oil and gas leases in part of Alaska’s National Petroleum Reserve. Interior Secretary Doug Burgum stated, "By rescinding the 2024 rule, we are following the direction set by President Trump to unlock Alaska’s energy potential, create jobs for North Slope communities and strengthen American energy security.“

Canada: Carney announces seven additional energy and natural resource initiatives being referred for fast-tracked approval. Calling them “transformational,” on November 13 Canadian Prime Minister Mark Carney announced seven major energy and natural resources initiatives being furthered, he said, to help Canada become more economically self-sufficient and realize its "full potential as an energy superpower.” Among the initiatives are the Crawford Nickel Project, an open-pit nickel-cobalt mine and on-site metal mill in Ontario; phase 2 of the Matawinie Mine Project in Quebec, which will produce graphite for defense applications and battery supply chains; the Ksi Lisims LNG – Natural Gas Liquefaction and Marine Terminal Project in British Columbia; and a massive hydroelectric project near Iqaluit, Nunavut. Carney stated that he is recommending that the new projects receive fast-tracked approval from the government's Major Projects Office. Fast-tracking approvals for the Iqaluit project, for instance, could bring it on line as soon as 2030.

Charge as you drive. A 1.5 kilometer stretch of France’s A10 now hosts Europe’s first wireless charging highway, using a system developed by Electreon Wireless Ltd. Electreon’s dynamic induction system can charge electric vehicles through the pavement as they traverse the roadway, potentially reducing reliance on off-road chargers and related vehicle downtime and enabling multiple vehicles to charge at once. The initial pilot is small, but France’s transport ministry aims to electrify 9,000 kilometers of highways by 2035. Electreon has been running similar trials in Detroit and elsewhere for two years.

Australia: CSIRO roadmap discusses role of novel carbon dioxide removal strategies in achieving net zero. This month, Australia’s Commonwealth Scientific and Industrial Research Organisation (CSIRO) published the Australian Carbon Dioxide Removal Roadmap, setting out the ways Australia may deploy a new generation of carbon dioxide removal (CDR) technologies to help it, and the world, reach net zero. The CDR Roadmap opens by stating, “To meet the goals of the Paris Agreement the world must reach net zero emissions. However, achieving net zero is only possible if countries simultaneously reduce emissions and remove CO2 from the atmosphere.” The roadmap then discusses a number of novel CDR technologies to help achieve that goal – such as direct air capture and ocean alkalinity enhancement – before estimating what would be required to develop and deploy them at scale in Australia. Such approaches, the roadmap emphasizes, would complement rather than replace more familiar CDR strategies, and their deployment could also inform CDR efforts around the world. The report also cautions that achieving CO2 reductions via CDR “will require action and collaboration across government, industry, research and community to drive technological development and create the right conditions to scale novel CDR responsibly.” While some of the approaches discussed in the roadmap are unique to Australia, the significance of the report extends beyond Australia’s borders as an example of how wealthy nations may deploy scientific research and collaborative efforts to achieve large-scale decarbonization. The CSIRO is the Australian government agency responsible for scientific research and its commercial and industrial applications. Find the downloadable roadmap on this page.

Sustainability in financial services

ICMA issues Climate Transition Bond Guidelines. Building on the Green Bond Principles, the International Capital Market Association (ICMA) this month issued new Climate Transition Bond Guidelines, a move being hailed by some observers as the “biggest change in sustainable finance in a very long time.” The Guidelines introduce a stand-alone Climate Transition Bond (CTB) label, a designation intended for use by high-emission issuers – entities in high-emitting sectors and/or with high-emitting activities – as they work to finance or refinance projects critical to achieving the goals of the Paris Agreement. The Guidelines also make a number of recommendations for high-emission issuers of climate transition-themed sustainability-linked bonds. See the Climate Transition Bond Guidelines here.

UK releases sustainability assurance standard. The Financial Reporting Council, the regulatory body governing auditors, accountants, and actuaries in the United Kingdom, has issued the UK’s adaptation of the International Auditing and Assurance Standards Board 2024 rules that govern sustainability audits. The UK version of the global benchmark standard, the International Standard on Sustainability Assurance (UK) 5000, “General Requirements for Sustainability Assurance Engagements,” is for voluntary use. This past summer, the UK carried out three consultations to inform the development of a UK-centric sustainability reporting framework. New rules and requirements are not expected before next year, and it remains unclear whether those new rules will make sustainability assurance mandatory. See the International Standard on Sustainability Assurance (UK) 5000 here.

EIB rolls out global-level Green Checker tool. The European Investment Bank Group (EIB) has rolled out global access to its Green Checker, a digital tool that allows financial institutions, small to medium-sized businesses, and governmental bodies to determine the eligibility of projects for green financing while assessing potential emissions reductions and energy savings. Before this, Green Checker was only available to entities within the EU. With its global launch, Green Checker has been expanded to include region-specific functionalities and simpler data input requirements. Access to the tool is free to encourage its use in emerging markets. The global expansion of Green Checker aligns with two EU initiatives: EIB’s Climate Bank Roadmap Phase Two, which has set a goal of doubling adaptation finance by 2030, and the EU’s Global Gateway strategy, a EU300 billion initiative to rally public and private investment in sustainable development via strategic partnerships by 2027.

Sustainability in the marketplace

New York: Pilot program to develop energy-efficient induction stoves for public housing. On November 13, the New York City Housing Authority, New York Power Authority, and New York State Energy Research and Development Authority announced the signing of a USD32 million contract with an appliance manufacturer to develop, pilot, and produce 10,000 new energy-efficient induction stoves for use in New York City public housing. The contract is the latest development in the New York Power Authority's Induction Stove Challenge, launched to prompt the development of energy-efficient induction stoves that can be installed in older buildings using standard 120-volt, 20-amp outlets.

Singapore introduces world’s first SAF surcharge on air tickets, outbound cargo. Singapore has become the first country to impose a sustainable airline fuel (SAF) levy on all departing air passengers. The measure, announced on November 11, also will affect outbound cargo shipments as well as general and business flights. The levy arises from the Singapore Sustainable Air Hub Blueprint, rolled out by the Civil Aviation Authority of Singapore (CAAS) in 2024, which aims to support the use of SAF to ensure the sustainable growth of the country’s aviation sector and cut emissions generated by the operations of Changi and Seletar Airports. The long-term goal of the Blueprint is to achieve net-zero domestic and international aviation GHG emissions by 2050. Among its near-term objectives is to switch at least one percent of all jet fuel used at Changi and Seletar to SAF by the end of next year. For air travelers, the modest levy will apply to all flight tickets originating in Singapore and issued after April 1, 2026. The levy will not affect passengers who are simply transiting through Singapore. Surcharges for cargo shipments will be determined by weight, ranging from SGD0.01 to SGD0.15 per kilogram.

Accenture report finds corporate support of net-zero targets is growing. A new report from professional services firm Accenture finds that corporate ambition to support the energy transition remains strong and that full net-zero target setting by the world’s largest companies has increased for the fourth year in a row. The report, Destination Net Zero, finds that a third of the G4000 and 41 percent of the G2000 (respectively, the world’s 4,000 and 2,000 largest companies) have set full net-zero targets covering Scopes 1, 2, and 3. Notably, the Accenture report states that nearly 90 percent of the G4000 are connecting their decarbonization efforts to business value: “Since 2016, the world’s largest companies have grown their revenues in aggregate by 7 percent a year while keeping overall operational emissions flat, demonstrating that decoupling growth from emissions leads to competitive advantage.” Destination Net Zero concludes with a “reality check,” observing that, despite current efforts, only 16 percent of the G4000 is on track for net-zero operations by 2050. See Destination Net Zero here.

Calendar

Key global reporting deadlines

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Coming events

• The 20th Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES COP20) takes place from November 24 to December 5, 2025 in Samarkand.
• The 7th session of the United Nations Environment Assembly (UNEA) takes place from December 8-12, 2025 in Nairobi.
• SF Climate Week takes place from April 18 to 26, 2026 in San Francisco.
• DC Climate Week takes place from April 20-26, 2026 in Washington, DC.
• The 2026 United Nations Climate Change Conference (COP31) will be held in November 2026 in Antalya, hosted by Turkey, with Australia serving as President of Negotiations.

For professional responsibility reasons, these summaries may not include discussions of developments relating to certain matters.