Emperor Sustainability Briefing 10.09.2026

Issue #29

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Staying Present

One of the challenges sustainability professionals face is reconciling the long-term nature of sustainability issues, with the action demanded right now. A UN report this week has conceded that the distant dream of limiting global warming to 1.5C is now officially impossible. We have to keep going – but even the best-case scenario of 1.8C is a concession in its own right. 

Addressing this challenge can involve making the most of what we can do in the present. Perhaps there are some clues in this fortnight’s Briefing: Spain calls for a robust plan to address EU climate impacts, the UK looks to prepare for El Nino, and climate scientists release company-relevant research from the latest model. It’s optimistic to keep calling for progress – but after a bruising 2026, there’s plenty to work on.

Regulations and Frameworks

UK: Significant overhaul to corporate reporting requirements, important impacts for sustainability 

On Monday, the UK Government published its highly anticipated proposal for Modernising Corporate Reporting, which will represent an overhaul of the current corporate reporting system. The 70 page document contains a lot of updates, but the broad drive is towards reducing burden and complexity, while ensuring that essential information is still included in reporting. You can find the full document here. 

Focusing on sustainability specifically, a number of updates in this document are of interest. Firstly, it is proposed that disclosures on a number of topics previously mandated by section 414 are made no longer mandatory – unless those topics are financially material to the company’s performance or operations. This includes environmental matters, employees, social matters and community matters, along with other topics. The government states that it hopes the removal of these items as “baseline” disclosures will encourage more thoughtful and insightful reporting by companies. For companies with exposures in these areas, we don’t expect these reporting topics to be dropped outright, but it may remove reporting burden from companies for whom these topics are truly not relevant.

SECR (emissions and energy) reporting is still required, but can be located anywhere in reports. On the incoming UK Sustainability Reporting Standards (SRS), it is shared that the FCA’s final decision on its listing rule (that is, how SRS will become mandatory for listed companies) is expected in autumn 2026, i.e. imminently. It is also shared in the document that the government is considering how to implement UK SRS into Companies Act 2006 – which is the mechanism through which SRS would become eventually mandatory for AIM-listed or private companies. One to watch!

Additionally, the government looks set to give companies greater freedom to decide where they want their sustainability-related reporting to be located in the Annual Report. A consultation is open until the end of November, accessible here. We’ll be sure to bring you further updates on this in future Briefings!

The Short List:

Maersk has partnered with Anemoi Marine Technologies to install the first wind-powered Rotor Sail system on a container vessel, aiming to improve fuel efficiency and reduce emissions through wind-assisted propulsion.

Microsoft and Norden are collaborating on a book-and-claim system for maritime fuels, making them more accessible and the associated emissions reductions more verifiable.

Policy

Food security concerns grow as UK braces for major El Niño event 

Building on our previous coverage of El Niño's effects on global supply chains, food security concerns are mounting closer to home as forecasts point to a potentially record-breaking event in the UK. El Niño is a climate pattern caused by unusually warm Pacific Ocean temperatures that can disrupt global weather systems and raise the risk of droughts, floods and extreme temperatures.

UK ministers and industry leaders have now warned this could add further pressure to global food supplies, against a backdrop of an already-strained UK agricultural sector following a summer of extreme weather. As well as food production internally in the UK being stressed, recent heatwaves have added pressure to imports too. The UK Environment Secretary Angela Eagle has recommended that households stock up on food supplies.

For companies in the food, retail and consumer sectors impacts from weather won’t come as news. However, with El Niño on the horizon, and international pressure on food imports, it’s a stronger reminder than ever that supply chain resilience is a live strategic issue with direct implications for commodity costs, consumer affordability, and public policy attention.

Spain calls for dedicated EU climate adaptation fund

The Spanish government is pushing the EU to create a dedicated climate adaptation fund, arguing that merely reactive policies are no longer sufficient to protect the continent from the effects of extreme heat. Madrid’s calculations put economic damage to EU countries from climate change at €822bn since 1980, with the summer’s heatwaves putting a fine point on just how regular and financially damaging heat events have become. While the EU has had an adaptation strategy for several years, there is a sense that the mood may have changed among EU countries, as pressures mount for a more coordinated, and more thoroughly costed, response. As part of its requests, Spain has also raised a more ambitious suggestion of revenue for the fund coming from a tax on the profits of oil and gas companies. France, for its part, has this month announced a €1bn aid package for farmers recovering from drought and heatwaves.

Corporate

Implications for scenario analysis: Latest leading weather model narrows scenarios

You’re either excited by the term “CMIP7” (that’s the seventh edition of the Coupled Model Intercomparison Project), or it sounds like a lot of jargon to you. Techy name aside, CMIP provides the foundational weather data for a large portion of the world’s climate change modelling and forecasts, including analysis done by companies for frameworks including TCFD. The upcoming version, CMIP7, will feed into the latest research and judgements of the Intergovernmental Panel on Climate Change (IPCC), the body that publishes the most widely used climate change scenarios.

While CMIP7’s data isn’t ready for public download yet, early outputs have given us a glimpse into how the IPCC’s scenarios (the “shared socioeconomic pathways”, or SSPs) might change, which would in turn form a new baseline for company climate scenario analysis. The seven new SSPs, replacing the previous five, cover a narrower scope of global warming ranges – 1.6C to 3.3C, from 1.5C to 4.7C – with the narrative surrounding the scenarios broadly describing a more densely populated and less wealthy planet. Scenarios that limit warming lean heavily on carbon dioxide removals, beyond just emissions reductions. They are an early indication that future scenario analysis – for instance to meet the incoming S2 sustainability standard – will be more precise, based around a tighter range of assumptions, and informed by a greater wealth of data.

Fashion sector’s emissions rose over 14% in the last two years

In a recent publication, fashion sustainability body the Apparel Impact Institute has reported that the industry’s global emissions climbed in both 2023 and 2024 (the most recent years for which there are data) for a total of 14% growth over two years. While a huge amount of progress has been made in fashion, and it’s been one of the sectors most subject to reputational and public pressures over emissions and supply chains, it seems that cost pressures and the growth of fast fashion have offset progress quite significantly. Increases were driven largely by increased global fibre production, especially polyester. There are some successes to point to: many more apparel companies have set targets for emissions reductions. However, it’s clear a lot of work is still required to achieve progress, and not only from the more cost-effective clothing providers: earlier this year, luxury products company Burberry delayed its net zero target by ten years. 

Deloitte caught in US anti-ESG crosshairs

The Big Four firm has been caught in the firing line of two of the latest anti-ESG initiatives in the US. At the end of August, Deloitte agreed to pay $21.5 million to settle allegations from the US Department of Justice’s Civil Rights Fraud Initiative, whereby race and sex-based goals influenced hiring, promotion and staffing decisions as part of its DEI programmes.

Shortly after, a coalition of 16 state Attorneys General warned all the Big Four accounting firms that their support for climate disclosure frameworks such as the TCFD and ISSB could create conflicts with auditor independence obligations and increase costs for businesses.

The news is the latest in the broader pressure being applied to corporate sustainability in the US from nearly all angles. While pressure on DEI initiatives is nothing new, it is notable that pressure is continuing on workplace diversity as well as on broader climate reporting.

One Number:

1.8C

The UN’s new best-case scenario for degrees of global warming caused by climate change. 1.5C, the previous target, is now out of reach – although UNEP’s report argues for an “overshoot, peak and decline” pathway through which we could return to this target level through net negative emissions.

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.