Emperor Sustainability Briefing 04.12.2025

Issue #10

Use the web form at the bottom of this page to sign up to receiving this bi-weekly newsletter straight to your inbox.

Beyond belief 

Credibility is at stake in this week’s Briefing. Adherents to the popular B-Corp framework are set to face extra scrutiny of their claims, and after another deforestation delay, the EU might see waning faith around its policy commitments. Meanwhile, the UK remains largely trustworthy around its climate programs in the latest Budget. 

COP30, for its part, has produced an outcome that won’t inspire much belief – while it only felt right to lead the Briefing with it, most of the sustainability action this time around has taken place elsewhere!

In this Briefing…

COP30 outcomes – B-Corp assurance 

SFDR revised – UK Budget outcomes 

Biodiversity obligations – Water scarcity 

EUDR delay – COP30 outcomes

Events

COP30: Some progress, but frustrating outcomes

Those who have felt that previous COPs – the UN’s global climate change summit – have been exercises in producing ‘plans to make more plans’ won’t find much to love from COP30’s outcomes. The text of the final agreement calls for the creation of a “global implementation accelerator” (a voluntary initiative on accelerating implementation actions), and a tripling of adaptation finance by 2035 – although developed nations have typically underdelivered on this promise in the past. References to a ‘roadmap’ for transitioning away from fossil fuels were cut, seen as a red-line by too many countries. As commented by the EU in the closing plenary, COP continues to miss a “concrete, annual process” for delivering action. 

Of note is that the IPCC, the scientific body which produces data used by many companies in understanding their climate exposures, was officially recognised as providing the “best available science” – a relief for those who feared this position would be watered down. 

As ever, it’s difficult to link the outcomes of these sweeping agreements back to the everyday work of sustainability. In broad, positives can be taken from the number of countries committed to cooperation on climate change, which some took as a sign that multilateralism was alive and well even during political headwinds. But COP30 also underscored the truth that the transition to net zero will remain a divided process, moving at different speeds for different parties.  

Regulation and frameworks

B Corps to undergo assurance check

B Lab has confirmed every certified B Corp will undergo audits by independent assurance providers from February 1st 2026. The change forms part of a new B Lab effort to ensure claims made within the framework are credible. 

It’s a step up in rigour for the framework, with assurance providers set to provide an assessment and corrective actions for companies seeking certification. As it’s still a voluntary framework, we expect assurance to be conducted in a way that helps companies meet the standards, rather than seeking to exclude them. Though B Lab have not clarified exactly how much more rigorous the new audits will be, the move represents an ambition to address previous criticisms around the certification’s laxness.  

The move marks an end to an active year at B Corp, with the release of its new certification process as well as its Impact Report to mark their 10th anniversary. B Corp remains a popular and successful framework, with Danone recently achieving worldwide certification – with their employees now representing around 9% of the total B Corp-company workforce. 

Finance

SFDR: PAIs to be cut, Articles 6, 8 and 9 revised

The European Commission has published a proposal to amend the Sustainable Finance Disclosure Regulation (SFDR), one of the oldest and most influential sustainable investment frameworks. The changes have been hailed as ‘market friendly’, in that they reduce reporting burden and complexity while still maintaining the core of the regulation. Entities selling financial products used to have to publish information on how they manage ‘Principle Adverse Impacts’ of investments, known as a PAI statement – long a thorn in the side of asset managers. In the new SFDR, these have been scrapped, although PAI indicators will still have to be published for individual financial products.

Articles 6, 8 and 9, the EU’s somewhat unwieldy categorisation system, will now become 7, 8 and 9 – Transition, ESG basics, and Sustainable, with 70% of a portfolio needing to align with the respective goals in order to earn the badge. This is down from 100% of a portfolio in the case of Article 9. This is set to rebalance the market quite significantly, with sustainability funds potentially becoming narrower and more precise. The revisions will now enter the EU legislative process, with final rules expected in 2026-27. 

Policy

UK Budget: Steady progress on Net Zero policy   

While media attention for the UK Autumn Budget was firmly on matters other than climate change, the Budget did deliver steady progress on net zero policy across a range of areas. Although major announcements were limited, there were a range of updates worth noting: 

• Plans to make energy cheaper: The government has committed to reforms aimed at lowering gas and electricity costs for households, reflecting recommendations from the Climate Change Committee. While these reforms are domestically-focused, lowering electricity costs in particular is important for the adoption of low-carbon technologies like heat pumps and EVs, and therefore important for decarbonisation goals. 

• Mixed outcomes on EVs: From April 2028, EV drivers will face a new charge of 3p per mile introduced under the electric vehicle exercise duty (eVED), which the OBR forecasts will ultimately reduce electric car sales. On the flipside, the electric car grant for supporting EV purchases will be expanded, along with charging infrastructure investments – notable for corporate fleets and for automotive retailers, as taken together these change the maths around EV affordability. A consultation has been published seeking view of the eVED’s implementation. 

• North Sea licences: No new oil and gas licences will be issued, a clear continuation of Labour’s stance on the North Sea.

• Nuclear gets a green badge: Nuclear is now included in the UK’s Green Financing Framework, which the government hopes will drive extra investment into nuclear developments. 

Considering the competing priorities of the Budget, it’s reassuring to see positions on climate change largely maintained – or at least not rolled-back. You can read a full round-up here. 

BNGain or BNGone? Government’s exemption proposals for Biodiversity Net Gain obligations  

Proposals to water down England’s Biodiversity Net Gain mandate (BNG) have sparked criticism among NGOs and key industry voices, with former Conservative Environment Secretary Michael Gove accusing the Labor government of a “sustained pattern of retreat on nature commitments”. The government is reportedly considering exemptions of new ‘smaller’ developments (under half a hectare), from BNG requirements. Alarmingly, this could mean 97% of planning applications face no obligations to improve natural habitats. Currently under the BNG scheme, all major housing and infrastructure projects in England are legally required to deliver a 10% uplift in biodiversity. 

A decision is still to come after consultations closed this summer. Critical voices including NGO the Wildlife Trust have criticised the step back, arguing that weakening a flagship nature requirement could undermine wider confidence in progress on nature – which comes as a disappointment in a year when nature has been more in the spotlight in corporate sustainability. 

Water scarcity could threaten UK net zero plans 

Research undertaken at Durham (funded by water retailer Wave) has suggested that development of water-intensive net zero projects could push some areas of the country into water shortage. New hydrogen and carbon capture projects could add an unmanageable amount of water demand, with the Environment Agency already forecasting drought in 2026. Aside from the additional planning pressure this might add for energy transition players, this analysis – and the accompanying risk – should also be on the radar of companies who have identified water as a dependency in their transition strategies. 

EU Deforestation Regulation likely to be delayed another year

The EU Deforestation Regulation (EUDR), its flagship regulation seeing to prevent imports of commodities from deforested areas, seems likely to have its implementation delayed to the beginning of 2027. After several flip-flops on the ruling, a tantalisingly close effective date of December 30th 2025 may not materialise after the EU Parliament agreed its intention to delay. The years’ postponement also opens up opportunities to further weaken the regulation. If your company has already prepared its stance on EUDR then this news will come as a disappointment, and likely make complicate your plans. Our recommendation (presuming the delay goes through) is to continue your implementation where possible, but keep an eye on the regulation throughout 2026 for further drawbacks. As EUDR hasn’t been scrapped, maintaining a baseline of focus in this area will eventually pay off – although no one can guarantee that the eventual ruling will have the same scope, which will unavoidably result in wasted cost and effort for some companies. 

One Number

86%

Of institutional investors in major markets globally, according to Morgan Stanley, expect to increase the proportion of their funds allocated to investments qualified as ‘sustainable’ over the next two years. North America led the pack, with 90% of those involved in the survey planning an increased allocation. 

Short list

Nike has agreed tie ups with two circular polyester providers to include the material in its mainstream athletic wear – taking it beyond pilot programs and one-off collections. 

Marks and Spencer has launched a new fashion supply chain decarbonisation program RE:Spark, alongside Schneider Electric. 

To discuss any of these topics in more detail or speak to one of our Sustainability team about how to better your corporate sustainability efforts, email [email protected] -we'd love to hear from you.