Emperor Sustainability Briefing 11.09.2025

Issue #4

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Nations in motion 

Spain’s action plan, China getting tough, France and Germany backing nuclear, and more – there’s something of a country-wide theme to this edition of the Briefing. 

Cutting across geographical boundaries are the GHG Protocol and ISO, set to release a global one-to-rule-them-all emissions standard, and EU’s deforestation regulation, which will pose extraterritorial challenges for forestry. 

You can expect a test on capital cities next week ;) 

In this briefing...

GHG / ISO link – SBTi power sector

EUDR arriving – Spain's emergency plan

China's regulation – EU SAF plan

US proxies stall – NZBA pauses

European nuclear

Regulation and frameworks

GHG Protocol and ISO to develop unified emissions standards

Comfortably the two most widely used and respected emissions reporting frameworks, the GHG Protocol and ISO’s 1406X family, are set to be merged into a coherent single standard – a welcome piece of consolidation. While no timeline has been set yet, the two organisations are set to collaborate to deliver a cohesive standard and “common global language for emissions accounting”. While the two bodies had never sharply diverged on the fundamentals of emissions accounting, the GHG Protocol’s standard tended to provide the blueprint for how disclosures should be approached by companies and initiatives, while ISO is foundational for verification and certification. A single framework means one point of truth for both disclosure and verification, with the joint future publication set to be definitive globally for reporting on emissions. Companies who already use a recognised GHG reporting approach will likely find no surprises in the future standard, but we will keep you updated on any planned changes to the overall approach.

SBTi publishes Power Sector Standard  

The Science Based Targets Initiative (SBTi) have published a first draft Power Sector Net Zero Standard, aiming to guide and support decarbonisation across the electricity and power industry. The draft was developed alongside the SBTi’s new and updated cross-sector Corporate Net Zero Standard, with key new criteria including a requirement for companies to have a plan to phase out unabated fossil fuel capacity, and to stop investing in unabated fossil fuel capacity. The consultation is open until November 3rd 2025, with feedback requested here. 

For your reading list:

Trellis breaks down the rise, and gradual fall, of the term ‘carbon-neutral’ – a concept beset by the difficult reputation of offsets and increased scrutiny over marketing terms. Whether or not you agree with the assessment, anyone using the term should be up to date with the conversation. 

Policy

EUDR looms, but supply chains are still playing hide and seek 

A new analysis by the Zoological Society of London has highlighted challenges likely to face forestry companies upon the introduction of the EU Deforestation Regulation (EUDR), set to enter into force from December 2025. According to the study, only 18% of the world’s largest tropical forestry companies currently disclose the countries which they source from. Any company with deforestation-linked supply chains should have EUDR front of mind, with stakeholders set to pay close attention to their supply chains as the regulation rolls out. EUDR is already creating extraterritorial effects, with Malaysia’s commodities ministry developing plans for ensuring the EU qualifies it as a low risk country for deforestation.  

Spain makes carbon reporting mandatory as part of climate emergency plan 

Spain has made carbon footprint reporting compulsory for large companies as part of its new climate emergency plan. Large firms will need to report scope 1 and 2 emissions from FY26, with the largest having to report scope 3 from 2028. The regulation is notable for it being a direct reaction to the floods and wildfires suffered by the country, with the emergency plan including the launch of a new national agency tasked with coordinating responses to climate-related disasters. It’s therefore one of the more energetic reactions, on a regulatory front, that we’ve seen to climate risk, as Spain reckons with an estimated £32bn in climate-related disaster losses over the past 5 years. 

China to roll out absolute emission caps and ETS 

China has intensified its carbon regulation strategy, with the government announcing that it’s set to introduce absolute carbon emissions caps in key industries starting in 2027. By 2030, the government envisages a fully established Emissions Trading Scheme (ETS). ETSs, such as the one adopted by the EU, provide emissions allowances to companies, and establish a carbon market which allow excess allowances to be sold between entities. Given China’s size as a market, any entities with supply chains linked to the country will want to keep a close eye on how this might impact costs. The move is undoubtedly a statement of grand intent, with one carbon markets analyst commenting that China sees carbon markets as “the key tool” for meeting its decarbonisation goals. 

European Commission backs global push for cleaner jet fuel 

The European Commission is putting €4 million behind a new global initiative to accelerate sustainable aviation fuels (SAF), aiming to cut emissions from one of the hardest-to-decarbonise sectors. The initiative signals growing pressure to engage with SAF – notoriously difficult to scale – as the sector aims to transition from ambition to action. Funding will support feasibility studies and production programs with an initial set of partner countries. 

Event:

Webinar: Storytelling in the era of data-driven disclosures

Tuesday 16th September – 10:00 GMT

With the first CSRD-compliant publications going live, reporters are thinking about how to meet extensive regulatory requirements without losing the storytelling that makes their communications sing. 

Tune in on the 16th to our webinar, held in partnership with ARKK and Pomelo, where we’ll dive into this challenge – you can register here now.

Corporate

Not one environmental shareholder resolution passed this US proxy season

A grand total of zero, out of 110 such resolutions tabled, passed at US listed companies this year – the first time in six years. Shareholders had previously used green proposals to encourage climate action from US companies, but given the country’s risk-averse environment around ESG, the approach has fallen flat in 2025. Resolutions peaked in 2022 with 14 proposals passed, with the drop-off reflective of the temperature around corporate environmental action. However, the diminishing number of resolutions passed is also reflective of the dropping popularity of resolutions as a pressure tactic altogether, after early successes in 2021. 

Finance

Net Zero Banking Alliance pauses activities  

The Net-Zero Banking Alliance (NZBA) has announced that it is pausing its activities following a wealth of high-profile departures from former members. The NZBA launched in 2021 when members committed to align greenhouse gas (GHG) emissions from their lending activities with net zero pathways by 2050, and to set 2030 targets for financed emissions. Departures from the group began last year with Goldman Sachs, followed by its Wall Street and Canadian peers, with UBS and Barclays being the most recent major departures in August 2025.  

Reasons for departures in North America are linked to the US’ anti-ESG movement and resulting political pressure, while in UK and EU, the later departures were due to earlier exits dampening the NZBA’s ability to support transitions. The group have proposed significant restructuring, shifting away from being a member-based alliance and initiating a vote to continue operating as a new framework initiative. The results of the vote are expected late September.  

Energy

France and Germany back nuclear financing 

France and Germany have both recognised nuclear energy as part of the EU’s energy transition after President Emmanuel Macron and Chancellor Friedrich Merz endorsed a bilateral energy roadmap. The agreement positions nuclear energy alongside other renewables with access to equal funding. France have been historically reliant on nuclear energy, but for Germany, this represents a sizable shift in policy since their complete phase-out of nuclear energy in 2023. 

One Number: One-third 

The amount of global plastic waste set to not be properly managed in 2025, according to Earth Action for Impact. With 225 million tonnes of plastic waste expected this year, around 72 million tonnes is expected to be improperly disposed of. Plastic Overshoot Day, falling on 5th September this year, marks the point when the world’s plastic waste generation exceeds its capacity to manage it sustainably.

The Short List

Sony has launched a new phase of its net zero roadmap, with targets including a 60% reduction in scope 1 and 2 emissions by 2030. 

Netflix has signed a 15-year contract with the American Forest Foundation (AFF) to purchase AFF’s verified carbon credits aimed at transitioning underused fields into forests in the USA’s south.

Deutsche Bank has reaffirmed its net zero goals in an updated Transition Plan, maintaining its 2050 target while adding interim milestones for 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.