Emperor Sustainability Briefing 12.02.2026

Issue #14

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Heading deeper

As sustainability reporting continues to mature, the frameworks and approaches which companies have access to are increasing in complexity and depth. In this Briefing alone, there’s a range of stories reflecting this trend: the GHG Protocol’s latest land standard launches new approaches for one of carbon accounting’s most complex areas. The SBTi levels up its approach to the automotive sector, enabling new commitments for challenging emissions categories. And carbon removals, often a controversial subject, receive detailed new methodologies from the EU. We’ve also had further insight into the timelines and scope for UK SRS – while a touch less ambitious, the new regulation will help to set the direction of travel for UK companies over the next few years.

Rewind half a decade, and while good intentions abounded, companies sometimes lacked the supporting infrastructure to put force behind their claims. Now, we see greater sophistication across the board – we’ve highlighted WE Soda below, who have impressed by publishing a separate Evidence Book alongside their science-based sustainability plan. Greater depth will make sustainability more challenging, and leaders will have to raise their level to match.

Contents 

UK SRS – SBTi automotive

GHG land standard – UK homes

EU carbon removals

Stories

Regulation and frameworks 

UK SRS offers evolution, not revolution, for reporting requirements 

After a long waiting period, an FCA paper has given us insight into how the new UK Sustainability Reporting Standards (UK SRS) are set to be implemented for listed companies. Overall, the news might be taken as something of an anticlimax, as in practice companies won’t have to go much beyond their existing TCFD reporting for at least the next two years.

You can read our full piece on the news here. With the caveat that these rules are not final yet, the key takeaways are given below:

• If you are in scope of TCFD, you will be in scope of UK SRS

• S2 (the climate standard covering TCFD content) will apply from FY27 reporting

• S1 (wider sustainability topics) will not apply until FY29 reporting

• Scope 3 emissions will apply from FY28 reporting, and on a ‘comply or explain’ basis

• Transition plans won’t be made mandatory as part of UK SRS

The FCA’s consultation closes on the 20th March. They aim to publish their final policy on UK SRS in Autumn 2026, and for this to come into force from 1st January 2027 (implementing the timelines described above). We still expect to see the final standards themselves issued by the government in February 2026, although it is not expected for these to change from the documents we have already seen (available here).

SBTi shifts up a gear with new automotive sector draft standard

The Science-Based Targets initiative (SBTi) has released the second draft of its net zero standard focused on the automotive sector. This sector-specific standard is designed to provide additional guidance and target-setting options to automakers or those who manufacture parts, with updates to this version of the standard largely focusing on how scope 3 targets can be set. Among a handful of changes, special attention is paid to scope 3 category 11, “use of sold products”, as this category has historically accounted for the majority of automakers’ indirect emissions. For category 11, companies will now be able to set targets based on the percentage of Zero-Emissions Vehicles (ZEVs) that they plan on making up their total sales – a change that should make target setting more straightforward, without reducing the ambition of targets.

If you’re in the sector and have struggled with setting achievable targets in the past, it’s worth reviewing the standard to see if it opens new paths for you – even as a shifting automotive policy environment continues to pose challenges to long-term planning.

GHG Protocol launches longawaited Land Sector and Removals Standard

After five years in development, the GHG Protocol has released its Land Sector and Removals (LSR) Standard – its first global framework for measuring land-use emissions and carbon removals. Given the Protocol’s role as the global default for carbon accounting, and the fact that agriculture and land-use change contribute around a quarter of global emissions, the standard is set to be highly influential.

From 1st January 2027, companies that currently account for emissions from land-use change, land management, or land products (e.g. agriculture) will be expected to report in line with the LSR Standard. Companies with these exposures will need to have their carbon accounting teams or suppliers assess the document carefully for how their current approaches align – although we note that the standard has, as expected, maintained many of the existing approaches to measuring these emissions types. To help with this, the GHG Protocol will publish supporting implementation guidance in Q2 2026.

By establishing an agreed protocol for measuring carbon removals and associated credits, the standard is also expected to provide a boost to the emerging removals sector, which has faced criticism for being difficult to verify and lacking comparability between approaches.

One notable gap is forest carbon accounting, which was excluded to avoid delaying publication amid unresolved technical disagreements. A further consultation is planned, and companies are currently being asked to disclose these emissions while being transparent about their chosen methods.

Reporting Highlight

WE Soda have published a new Sustainability Plan, homing in on a clear, science-backed strategy for sustainability performance within the business. We loved that the report was launched as part of a ‘trilogy’ of reports, accompanied by an Evidence Book and ‘Case for Change’ covering global trends – a leading approach for putting robust research behind the company and sector’s sustainability transition. 

Policy 

UK homes turn up the heat (pump), with a record-breaking year for renewable technologies 

The UK saw another record year for smallscale renewable tech in 2025, with 369,000 installations of solar panels, heat pumps and home batteries, representing a 34% increase YoY. That equates to roughly one installed every 90 seconds. This is according to data from MCS Foundation, a certification body for home renewable technologies, with the organisation attributing the momentum to a combination of stronger government incentives and a big push from newbuild developers, with 28% of installations on new-builds. Given the country’s older housing stock, which is often less energy efficient, residential buildings have typically been a ‘hotspot’ for the UK, accounting for around a quarter of the UK’s emissions. With more than a quarter of installations receiving some level of government support, and the upcoming Warm Homes Plan promising £15bn this Parliament, companies can expect the policy drivers behind this surge to continue.

EU adopts first ever standards for carbon removal projects

In a nice pairing with the GHG Protocol standard covering removals, which you can read about above, the European Commission has this month published the EU’s first voluntary certification methodologies for carbon removal projects. These cover three types of activities – direct air capture and storage (DACCS), biogenic emissions capture and storage, and biochar carbon removal. By defining methodologies such as what counts as a tonne of removal and how permanence of removal has to be ensured, it’s another step towards creating greater consistency within the removals market, with one representative from a DACCS provider commenting that the methodologies offer “a blueprint for a global carbon market”.

One Number

38%  

According to MSCI, the number of listed companies globally whose emissions trajectories are currently aligned with limiting global warming to under 2°C, with the remaining 62% of companies on course for a trajectory that exceeds this limit.

Short List

Deutsche Bank posted its strongest annual sustainable finance and ESG investment performance since 2020 in 2025, reaching a total of €98 billion total volumes for these areas.

Levi’s launched a global campaign, the ‘Levi’s Wear Longer Project’, to share lessons on how to make clothes last longer through repairs and alterations.

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.