Emperor Sustainability Briefing 06.11.2025

Issue #8

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Sweeping commitments and underlying action

Big moves and topline targets often capture the headlines, but these kinds of far-ranging goals are intended to be the platform for tangible, smaller-scale action. We’re interested in both: helping you keep abreast of what the EU bloc is targeting by 2040 and trying to show what that might mean in the short-term. 

On the former point there’s plenty of bedtime reading this week, with the UK issuing a 238-page Climate Plan update, and COP30 creeping (somewhat sluggishly) towards its 10th November start date. As ever, if you’re looking for the read-across into your own strategies, we’re happy to chat. 

In this Briefing...

UK Climate Plan – New Zealand thresholds

Ratings agencies regulated – Omnibus business survey

COP30 muted – Nature in strategies

TotalEnergies ruling

Policy

We’re “all in” this together: UK Government updates Climate Plan

The UK government has published a 200-page long update to its climate strategy, now with the more precise title of ‘Carbon Budget and Growth Delivery Plan’. A long and wide-ranging piece, we would encourage any companies within affected sectors to analyse relevant policy commitments for themselves, as a topline summary would be insufficient. What is useful for all parties, is the Plan’s bringing together of various commitments into one holistic document: take it as a minor ‘reset’ of the government’s position, laying out how the current administration sees the next 15 years of decarbonisation being met. Energy Secretary Ed Miliband says the UK is “all in” on climate action, despite political pressure from Reform UK and some Conservative voices calling for a fossil-fuel revival.

While the frequent changes in recent years to decarbonisation policy – and the general lack of surprises in the document – have led to a somewhat underwhelming media response, it remains a significant piece of work that businesses of all sizes will be looking to for the foundations of bankable commitments on strategy. In broad, the Plan sets out how the UK intends to meet Carbon Budgets 4-6 (to 2037), with affected sectors now waiting for exact details on policy – as is usually the case with these larger and more sweeping documents. A few of the headline goals are:

• 9.3 million heat pumps in UK homes by 2035

• 21% of all cars on UK roads being Zero Emissions Vehicles (ZEV) by 2030

• £40 billion into electricity network and infrastructure

• 22% Sustainable Aviation Fuel in planes by 2040

With the Plan set to (hopefully) provide a baseline for policy direction, companies in the most transition-affected sectors will watch closely in the next few months as the document is tested in political spheres and by industry opinion.

New Zealand scales back climate-related disclosures 

The Government of New Zealand has announced a significant increase in the reporting threshold for its Climate-Related Disclosure (CRD) regulation, pushing smaller companies out of scope. The CRD, which was launched in 2021, introduced TCFD-style climate change risk and opportunity reporting for large financial bodies and listed companies. A significant lift in market cap thresholds will reduce reporting entities by about half. With only 34 companies listing on the country’s NZX stock exchange since 2020 a desire to reduce reporting burden is, as usual, the primary goal of this rollback, which makes New Zealand the latest jurisdiction to temper its sustainability regulation.

UK FCA given powers to regulate ESG ratings providers

Legislation has now passed enabling the UK Financial Conduct Authority (FCA) to regulate ESG ratings agencies, in alignment with similar regulatory developments in the EU and Asia. It’s an expected next step for the maturing space, with any area claiming to provide investor-relevant data also naturally being subject to firm regulation. The FCA plans to publish its proposed rulings before the end of 2025, which are expected to draw on recommendations from the International Organization of Securities Commissions (IOSCO). Regulation is currently expected to come into effect in Summer 2028. 

Regulation and frameworks

EU businesses push back on diluted due diligence directive

As we wait for the next EU Parliament vote on the Omnibus proposal, slated for the 13th November, we can take a look at the mood in the corporate landscape in response to the proposed updates. A survey, carried out by independent business association #WeAreEurope, in partnership with the Wageningen University, found that almost 60% of European companies surveyed do not want the original Corporate Sustainability Due Diligence Directive (CSDDD) to be diluted. Interestingly, 77% of the 160 respondents already conduct due diligence activities, and one in three state they have directly benefitted from the activities. 

The Omnibus proposes to slash the number of companies affected and minimise due diligence requirements to only focus on direct suppliers. However, more than half of the survey respondents say that’s a mistake, arguing that it forces European SMEs to complete “meaningless paperwork without empowering them to address the real risks within their supply chains.” With the vote looming, and mixed reactions to the proposal, we will certainly keep you updated in our next edition. 

Events

Limited excitement in run-up to COP30

In previous years, the run-up to the Conference of the Parties (COP) – the UN’s flagship climate conference – has seen a flurry of articles, opinion pieces, and public debate. With three days left to go and a palpable lack of buzz, we feel safe in claiming that COP30 has attracted substantially less attention than previous COPs.

Discussions have largely circled on the merit of holding the conference in the Amazon region rather than on impending negotiations. This is likely a result of general fatigue from both countries and the media around the conference, with discussions almost always proving sluggish and unsatisfying. 

So far, only 64 countries have submitted updated carbon reduction plans, the US has essentially withdrawn, and climate has dropped further down national agendas over the course of the previous year – which raises bigger questions over the general effectiveness of establishing annual global agreements, if countries do not then expend effort on meeting them in the intervening period. Negotiators will hope to ride the momentum of successful shipping talks, with discussions at COP30 set, as ever, to be wide-ranging. Often, we do see significant and encouraging progress made on certain fronts, while others stall. The wider focus this year will be on agreements to strengthen national climate plans, and further steps on COP29’s commitment to $1.3 trillion in finance for developing countries. We’ll update you in a future Briefing as to how far the talks get, and the key takeaways for companies. 

Corporate

Nature finds more space in strategies; food and drink handbook launched

A report from business coalition Business for Nature found that 50% of nature strategies, among 32 companies analysed, received Board-level oversight, with a number of companies also linking remuneration to nature-related targets. While nature is still seen as more leading-edge than other areas of sustainability given its overall complexity, it feels that every week we see further corporate action in the space. This week also saw the food and drink sector get a tailored nudge, with industry body The Food and Drink Federation launching a new Nature Handbook. As one of the more exposed sectors, the Federation is seeking to make the task easier for companies in the sector who are starting to formulate an understanding of their nature-related impacts and risks. If you’re interested in understanding more on TNFD reporting or the nature landscape, do get in touch with our team to set up a chat. 

TotalEnergies ordered to remove green claims

A court in Paris has found green claims made by oil firm TotalEnergies to be misleading and ordered it to remove them from its website. The case was brought by NGOs including Greenpeace, and marks the first time in the country that an energy major has been held accountable for deceptive environmental claims; specifically, language on being a “major player in the energy transition” and “on the path to net zero by 2050”. 

Energy companies which are involved in both fossil fuels and renewables are generally being met with lower levels of patience around ‘supporting the energy transition’-type claims, not least as it’s been several years now that such claims have been being made, with a desire to see credible transition plans for how an expected pivot into green energy will be achieved. In the same week, TotalEnergies has said it is close to starting up its $20bn gas plant in Mozambique. 

One Number

90% 

The European Commission’s proposed target to cut net EU greenhouse gas emissions by 2040, against a 1990 baseline. EU climate ministers are making a last attempt to pass a new climate change target this Tuesday, before COP30, after failing to agree on a 2040 climate target in September. The proposal has been met with mixed reactions, with Italy, Poland, and the Czech Republic warning that it is too restrictive, whereas the Netherlands, Spain, and Sweden point towards worsening extreme weather events and the need to catch up with China’s green technology manufacturing as strong reasons for ambitious targets. 

Short List

H&M has partnered with Barcelona-based textile recycler Recover to integrate recycled cotton across the supply chain, with the goal of boosting circularity and reduce virgin fibre usage. 

Nespresso can claim the world’s first “regenerative coffee,” meaning coffee grown in a way that aims to be restorative of ecosystems, after launching a new certification alongside long-term partner the Rainforest Alliance. 

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.