Emperor Sustainability Briefing 09.10.2025

Issue #6

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Sorry miss, a dog ate my Briefing

Ever had to craft an excuse? A letter to the EU Commission this week asked for yet another year of delay to deforestation regulation, due to… an unready IT system. I should’ve had that one in my back pocket for the first day of term. 

Elsewhere, it’s top marks. The SBTi Academy opens to students, the FRC gives a good grade to TCFD reporting, it’s a passing result for the High Seas Treaty, and California comes top of the class for US sustainability regulation. NZBA, however, has finally dropped out. 

In this Briefing…

EUDR delay – Seas treaty passes

California disclosures – SBTi Academy

FRC review – EU solar shines

NZBA shutters 

Policy 

EUDR delay due to *checks notes* faulty IT system

A few weeks ago, we shared the news that a large proportion of companies exposed to forestry and timber were likely to struggle to comply with the EU Deforestation Regulation (EUDR), the EU’s flagship regulation for preventing products which contribute to deforestation from entering the EU market. Those companies can breathe a little easier, because EUDR, which had been set to come into force from January 2026, might now be subject to yet another year-long delay. The reason? IT systems which may not be able to handle the data load. This prompted some eye-rolling across the board – and a healthy dose of scepticism around the cause of the delay, given that other EU sustainability regulation has been rolled back or delayed in recent years. 

For their part, large players in spaces with deforestation-exposed commodities, including Nestle, Mars Wrigley and Ferrero, have issued a letter warning against the delay. As we saw with the EU Omnibus, companies place a high value on consistency and clarity, with sudden changes to major regulations being capable of causing greater headaches than actual compliance. Many companies had invested heavily to meet EUDR’s 2026 start date, with the letter stressing concerns that further postponement would put forests at risk and slow action. 

California climate disclosures to capture 4000+ companies 

With the current US administration rolling back ESG regulation, California is pushing against the current. The state’s new climate disclosure laws will see over 4,000 companies having to comply with a list released by the California Air Resources Board (CARB – tantalizingly close to ‘CARBON’, by the way) at the end of last month. These disclosures are prompted by regulations SB 253 and SB 261 and will affect the majority of S&P 500 constituents, showing significant reach from the notionally state-level legislation. They mandate emissions reporting on scopes 1+2, with scope 3 to follow, along with TCFD-style disclosures on climate risk and opportunity. 

This represents a fairly major move in US regulation after the SEC’s climate disclosure rules became less likely to materialise just weeks ago. There appear to be further green shoots emerging after a recent survey by Net Zero Tracker found a 9% increase in net zero commitments in U.S firms within the last year. While many companies aren’t talking about sustainability in the same way after Trump’s re-election, many are pressing on with action, likely aware that while political winds may eventually shift, climate change isn’t going away. If you’re working on wrapping your head around these new rules, get in touch with our team and we can talk things through. 

The tides have turned: High Seas Treaty to come into force in January 2026

After two decades of negotiations, the High Seas Treaty has officially hit its ratification threshold. Morocco became the 60th country to ratify the agreement, meaning it will enter into force in January 2026. Signed by 84 countries in 2023, the treaty is the first legally binding framework to protect the high seas (international marine waters outside of the jurisdiction of any country) which covers about two-thirds of the world’s oceans. Currently, just 1% of these waters are protected. The treaty sets a target to reach 30% by 2030.

Once active, countries will propose areas for protection, which will be voted on by treaty members. The timing is critical: the Potsdam Institute for Climate Impact Research’s annual assessment shows ocean acidity, largely driven by fossil fuel emissions, has crossed a threshold that threatens marine life for the first time, adding urgency to the treaty’s implementation.

Finance

NZBA votes to cease operations 

The Net-Zero Banking Alliance’s (NZBA) remaining members have voted to transition away from being a member-based alliance, and will now publish its guidance as a framework instead, thereby signalling the immediate ceasing of operations. The NZBA has been in-and-out of the news (and the Briefing) over the last few months, as many of its key members gradually left the group. After rapidly expanding to over 140 banks after formation in 2021, representing $74 trillion’s worth of total assets in 2024, the organisation was never quite able to establish itself as a major player, and its influence suffered when the going got tough. The group’s framework will continue to provide guidance for banks setting decarbonisation targets, and support for their transition plans. 

Regulation and Frameworks

SBTi launches first training platform and expert register 

The Science Based Targets initiative (SBTi), which publishes the most widely respected standard for emissions reductions targets, has now launched its SBTi Academy training platform. The platform offers training to sustainability professionals on setting targets and understanding the technicalities of the SBTi’s often-complex standard, with completion of the course conferring a position on the SBTI’s own register. Companies have often looked to consultancy support to handle SBTi submissions, with the launch of the Academy the latest move from the organisation to formalise the overall process. Last year the organisation launched SBTi Services, a spin-out which performs the validation of submitted targets, in order to create greater transparency and simplicity. 

TCFD and climate reporting is generally pretty good, says FRC

UK reporting regulator the FRC has published its Annual Review of Corporate Reporting. As well as a useful retrospective, the document is the organisation’s way of setting the tone for reporters and auditors on the areas where it wants to see improvement and greater scrutiny. Sustainability professionals may be quietly pleased to know that the FRC had very few comments on TCFD and CFD this year, noting the greater level of familiarity with the framework across the board. The FRC did note that companies should always make sure that material financial impacts reported in the climate frameworks are accurately reflected in the back-end of reports, to ensure consistency – a common stumbling block. With the slightly more rigorous UK Sustainability Reporting Standards (SRS) S2 on the way to replace TCFD in future years, it’s promising to see that companies have generally achieved good reporting in this area. 

From our part, we’ve seen companies start to excel at this particular disclosure, particularly on the integration of its outputs into financial disclosures and risk management systems. If you’d like to take your climate reporting and TCFD work to the next level, or hear about what might be on the way from new regulations, then please be in touch with a member of the team. 

Energy

Here comes the sun: Solar rises to lead EU’s electricity mix 

June 2025 saw a milestone: solar energy became the EU’s top source of electricity for the first time, generating 22% of the bloc’s power. It just edged out nuclear (21.6%), wind (15.8%), hydro (14.1%) and natural gas (13.8%). The surge helped renewables hit 54% of net electricity generation in Q2, up 1.3% year-on-year. Solar alone produced over 122,000 GWh, enough to power around three million homes. According to leading solar developer Alight, a major driver is the speed of deployment: a solar farm can be developed in just a year, compared to slower spin-up times for other sources. 

One Number:

5%

Based on policy changes in China and the US, the International Energy Agency has cut its global renewable growth forecast by 5%. China, for its part, still remains on track to meet its recently announced 2035 wind and solar target five years ahead of schedule. 

Short List:

Waitrose has become one of the first five organisations to join a pilot group to develop the world’s first verified ocean science-based targets for the seafood sector, using the Science-Based Targets Network’s (SBTN) recently released guidance. It aims to have 100% of own-brand fish and shellfish to come from third-party verified responsible sources by the end of 2025. 

P&O Ferries recently announced that, following a successful trial, its Pride of Hull passenger Ferry between Hull and Rotterdam is now running entirely on Biofuel B30. The blend of 70% fossil fuel and 30% biodiesel made from animal fats and cooking oil is expected to reduce emissions by 20%. 

Tesco is now stocking shelves with broccoli from its low carbon concept farm in Lincolnshire, with around 50 tonnes now on sale. 

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.