Emperor Sustainability Briefing 09.04.2026

Issue #18

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Land, sea and skies

There’s a satisfyingly complete geographic scope to this edition’s stories. The government has released a new framework governing land usage in England, an assurance scheme for aviation fuels aims to reduce pollution in the skies, while a leading water stewardship initiative gets a refresh. If the Artemis rocket had been running on recycled biofuels, we could’ve added outer space to the list too…

Also launching this week are important developments from the ISSB on its nature approach, and major updates to regulations for Swiss companies. Separately, EFRAG seeks insights on its upcoming approach to voluntary ESRS reporting. 

Contents

Land framework – ISSB nature

EU ETS – EU waste

Aviation fuel – Voluntary CSRD

Swiss regulation – Water stewardship

GRI on pollution

Reporting Highlight

TITAN Group – one of the leading international businesses in the building and infrastructure materials industry – launched their Integrated Annual Report last week. As well as presenting the strategy execution, results, sustainability and digitalisation progress, alongside key achievements in the year, a new double-page spread depicts their full value chain, complete with sustainability impacts. 

Stories

Policy

Soil Searching: England’s long-anticipated Land Use Framework finally published  

The UK government has published its long-awaited Land Use Framework for England, which provides guidance on how the country’s land can juggle the competing priorities of climate targets, nature recovery, and food production. The headline finding is that England has enough land meet its objectives across these areas. However, the plan also acknowledges the scale of the trade-offs ahead: more land is needed for trees, peat and nature restoration in order to meet climate and biodiversity goals, without hollowing out domestic food production. 

Any companies with significant UK land ownerships, or land use strategies of their own, should assess the document, as its findings will help to shape the future terms of debate. Some key statistics to be aware of from the plan include: 

• 70% of land in the UK is currently used for agriculture, primarily livestock  

• Only 1% of England’s land will be required to be taken up by renewables by 2050 to meet its targets  
• 6% of England’s land should be used for achieving climate and nature goals 

It’s worth noting that the Framework doesn’t represent a legally binding plan, but is intended to help inform decision making around land use. 

ISSB edges towards nature disclosures; SASB updates

The ISSB has tentatively agreed its next move on nature, opting for “incremental requirements and guidance” rather than a full standalone standard. The focus will be on how nature related risks and opportunities affect strategy and decision making, including how companies plan to respond, even where this isn’t wrapped up in a full transition plan. This approach aligns with the structure of the TNFD standards, which was to be expected after TNFD was brought within the ISSB last year. You can read the summary of the meeting here. 

The ISSB has also published new exposure drafts proposing updates to several sectorspecific SASB standards, including agriculture and electric utilities. 

EU ETS lobbying begins to yield fruit

The EU’s Emissions Trading System (ETS) – its flagship carbon pricing system designed to incentivise decarbonisation – has faced calls to be weakened since the current energy crisis began. Last week, the EU Commission for the first time tabled a motion to increase the supply of carbon allowances within the system, in order to support industries faced with higher costs. Commentators expect the Commission to follow up in due course with further changes. 

While many had been calling for ETS to be reviewed since before the conflict in Iran, there’s no doubt that high energy prices have accelerated the process. While critics have argued that weakening the ETS would cause long-term damage to investment in decarbonisation, others view the current crisis as a short-term price spike which required an immediate response. EU companies whose operations are affected by ETS should keep an eye on the news for further developments. 

EU introduces guidance on its waste regulation (PPWR)

Packaging waste across the EU reached a figure of 178kg of waste per person annually in 2023, a number expected to increase by 19% by 2030 without intervention. To address this trend, the EU Commission has released guidance intended to help member states with the implementation of the Packaging and Packaging Waste Regulation (PPWR), the EU’s primary packaging regulation. 

With the guidance providing practical direction on common areas of uncertainty within the regulation, the hope is that the Commission’s release will improve consistency between countries, and increase the speed of uptake into national law. Companies who are affected by the regulation, or who are continuing to work on reducing their own waste impacts, would do well to assess the EU’s guidance – as it may well influence how PPWR rules are implemented at the national level. 

Regulation and frameworks

EFRAG consulting on voluntary ESRS-style standards for companies out of CSRD scope

EFRAG, the body responsible for developing the ESRS standards, has opened a call for input from organisations to help it develop guidance on voluntary ESRS reporting. With the EU’s Omnibus package leaving many large European companies out of scope of mandatory CSRD reporting, this new guidance will be designed to meet demand from voluntary reporters, who are interested in keeping up near CSRD-level reporting in order to meet stakeholder expectations. 

It’s unclear for now if this guidance will emerge as a new, stripped back version of ESRS, or simply as official reporting recommendations. But with many companies weighing the benefits of ESRS adoption, a more codified approach to what voluntary reporting should look like is welcome. 

New law aligns Swiss companies with CSRD, CSDDD

Switzerland’s regulatory framework for sustainability has for the past few years been, quite literally, a law unto itself – with Switzerland’s position as non-EU, but willing to implement robust climate and sustainability standards. This includes its Ordinance on Climate Disclosures, which requires GHG emissions disclosures, TCFD-style reporting and transition plans. Switzerland has now taken its next step with its proposed Federal Act on Sustainable Corporate Governance, which is set to broadly align obligations for Swiss companies with those of EU ones in the scope of CSRD and CSDDD – the latter of which implements due diligence obligations across the value chain. The CSRD-style rulings are currently set to apply to companies with at least 1,000 employees and a balance sheet of CHF 450mn, while the CSDDD-style ones will apply to large companies – at least 5,000 employees, and a balance sheet of CHF 1.5bn.

If you’re set to be exposed to these Swiss rulings and would like to have an initial discussion on consequences for your reporting, then please be in touch with us, as we’d be happy to talk it through. 

Popular water stewardship standard now CSRD-aligned 

The Alliance for Water Stewardship has published version 3.0 of The International Water Stewardship standard (also known as AWS) after two years of consultation. One of the main outcomes is that the standard is now more closely aligned with CSRD requirements. AWS has over 240 members, including big names such as Unilever, Coca-Cola and Diageo. With the hopes of increasing adoption, the new framework has also cut the number of requirements it contains by 27%. 

A more standardised and relatable framework such as this comes at a useful time, with more companies than ever disclosing on water. One to check out if water is a material topic to your business and reporting. 

GRI release draft Pollution standard  

GRI have published exposure drafts for Air Pollution, Soil Pollution and Critical Incidents as part of the GRI Topic Standard Project for Pollution. They are open to consultation until 8th June 2026.  

Corporate

Sustainable Aviation Fuel (SAF) gets a UK assurance scheme 

RFAS Aviation will extend the existing UK Renewable Fuels Assurance Scheme, which had applied only to road transport, into the skies, with its audit and assurance framework for fuels being applied to the aviation sector. SAF has so far seen a relatively slow scale-up due to a lack of a standardised approach, alongside difficulties in producing large volumes of fuel. One of RFAS Aviation’s goals will be to make emissions reductions claims more credible, to incentivise further purchasing and investment. The UK is aiming to cut around 6 million tonnes of carbon from the aviation sector by 2040, with SAF expected to make significant contributions. 

One Number

€8bn

The amount of money made available in Germany’s new climate plan, to fund measures including wind power capacity and schemes to boost EV sales. Germany is targeting carbon reductions of 65% by 2030, against 1990 levels. 

Short List

Radisson Hotel Group have announced a target of reaching 100 net zero hotels globally by 2030

Volvo have begun on-road testing of hydrogen-powered heavy trucks, with a goal of commercial launch before 2030

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.