Emperor Sustainability Briefing 12.03.2026

Issue #16

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Signed and sealed

Two of the past year’s biggest sustainability reporting items reach the finish line this Edition, with the EU’s Omnibus package being written in to law, and UK SRS being published in its final form. Aside from the welcome clarity this provides, the Briefing team can report that we’ll be happy to not have to re-write our requirement summaries every few weeks. 

Elsewhere, Anglo American publish their inaugural climate transition plan, complete with an explanatory paragraph on their SBTi challenges, whiles Wales adopts landmark new biodiversity targets. Enjoy the rest of your Thursday – your own finish line is in sight!

Reporting Highlight 

Lloyd’s Banking Group’s launched their reporting suite this week. We loved the focus on ‘Purpose in action’ pages in the Sustainability Report – putting real weight behind their sustainability focuses with an emphasis on human stories and enterprises. 

Contents

UK SRS published – Omnibus finalised

Anglo transition plan – California regulations

Wales targets – Saab's carbon

Stories

Regulation and frameworks

Final UK SRS published; no new news on scope

The UK SRS, the UK’s implementation of the ISSB Standards (i.e. IFRS S1 and S2), have now been published in their final forms. As expected, no new amendments have been made to the actual content of these standards since we saw them last year, meaning they are essentially consistent with the IFRS standards – requiring TCFD-style disclosures on both climate (S2) and wider sustainability topics (S1). The question now turns back to which companies will be in scope. For now, the FCA’s position is that companies which are currently in scope of TCFD will come in scope of UK SRS. However, S1, which represents the bulk of the ‘new’ content companies will have to tackle, will currently not be in scope until FY29 reporting – quite a long way off. Read our summary on how UK SRS will apply here, and let us know if you’d like to discuss what this is likely to mean for you. 

Omnibus package *breathe* finally signed off 

After a long wait, we now have final clarity on the EU’s CSRD and CSDDD frameworks, following the Omnibus directive. With the ‘Omnibus I Directive’ published in the official journal and set to come into force next month, the changes to these sustainability regulations are now EU law. Member States will now have 12 months to transpose amendments into their own national laws. 

You can find a full breakdown of the agreed changes in an earlier briefing here, or refer to the calendar at the bottom of the Briefing. With this last sign-off, the uncertainty that companies have been facing over scope and timelines has, for now, been brought to an end – allowing more space to focus on strategy and reporting approach. If Omnibus is relevant to your business, then you’ve probably already considered its impacts closely. But if you’d like to catch up with the Emperor team on this, or hear from how we’re seeing entities deal with the changes, do be in touch. 

Corporate

Anglo American skips SBTi accreditation in transition plan

Anglo American, one of the world’s largest mining companies, has published its 2026-28 climate transition plan – which, notably, contains an open acknowledgement that it hasn’t been possible for it to achieve SBTi verification of its climate targets. The report includes a direct comparison with the decarbonisation trajectory required by the SBTi, the world’s foremost carbon target standard setter. But Anglo have conceded that the stringency of this trajectory, along with the SBTi’s position on coal, have made it impossible for them to align.

Anglo American’s choice to proceed without the SBTi may be a quiet ‘rubber hitting the road’ moment for the mining sector, which has repeatedly warned that the stringency of the organisation’s scope 3 requirements may encourage straightforward divestment of carbon-intensive assets, rather than actual decarbonisation. With the transition plan proceeding without the verification stamp, the move suggests that in hard-to-decarbonise sectors, the SBTi risks losing some of its relevance. This feels especially acute given the scale of the overall commitment being put into Anglo’s plan – suggesting that it is not for lack of effort that the SBTi’s requirements have proved too challenging. Their example may be instructive for companies who are coming up against similar challenges in their transition planning. 

Saab’s internal carbon price rollout reflects wider trend

Saab is the latest large company to announce it will introduce an internal carbon price, with the Swedish defence company positioning the price as a tool to close the remaining “financing gaps” in its 2050 decarbonisation roadmap. Saab says the pricing mechanism will help compare the cost-effectiveness of reduction measures and guide climate-related investment decisions.

For those less familiar, an internal carbon price sees companies assign a notional monetary value to each unit of carbon – even if there isn’t yet a real compliance cost associated with that carbon – as a tool to aid in future-proofing decision making. 

While such prices have long been a feature of large firms, we’re increasingly seeing them be discussed within company communications as a marker of more sophisticated sustainability strategies. The World Business Council for Sustainable Development (WBCSD) recently published a guide recommending carbon prices, with the guide observing that real carbon taxation systems now cover around 28% of global emissions. 

Policy

California sets deadline for emissions reporting

The California Air Resources Board (CARB) has unanimously approved the adoption of the Climate Corporate Data Accountability Act (a.k.a. SB 253), and the Climate-Related Financial Risk Act (a.k.a. SB 261). These will respectively require over 4,000 companies to report their GHG emissions, and mandate TCFD-style climate reporting. 

Under current timelines, the first deadline for scope 1 and 2 emissions reporting for companies would fall in August of this year – however, the regulation still requires final approval from the Office of Administrative Law, which has a mixed history of approving climate-related regulation. SB261’s future is also uncertain, with CARB facing legal challenges, although under the assumption that the ruling will become law over over 120 voluntary SB 261 reports have been published already.

California’s progress has been watched closely in Europe and the UK, as the two regulations notably target entities ‘doing business in California’, rather than only those headquartered there – meaning a significant extraterritorial reach. We anticipate that a good number of companies large enough to be doing business in both Europe and California will have these requirements covered already. But if this applies to you, then it’s worth keeping tabs on when these acts may come into force. 

Wales adopts first legally binding targets for nature recovery

Wales has just passed a landmark Environment Bill that will force Ministers to set the nation’s first legally binding biodiversity targets, a major step forward for UKlevel nature policy. The bill has also been recognised as a important step, given that the UK is considered to be in the bottom 10% of nations globally in terms of biodiversity intactness. 

The legislation updates Wales’ 2016 environmental framework and introduces the ‘Office of Environmental Governance Wales’, a new office for holding public bodies to account on environmental law and target delivery. Targets set will be aligned to the UK-wide revised Environmental Improvement Plan, released in December 2025.

With the 170+ signatories of the UN-convened Global Biodiversity Framework agreed in 2022, set to come together in Armenia this October to assess progress against its targets, Wales’ move adds pressure on governments to shift nature from an emerging topic to a governance reality. 

One Number

49%

Nearly half (49%) of all clean Power Purchase Agreements (PPAs) volumes made globally in 2025 were accounted for by just four tech companies: Amazon, Meta, Google and Microsoft. While the growth in energy demand reflected here has been driven by AI buildout, it’s promising that at least some of this demand is being met by large renewables deals. 

Short List

Toyota is set to build a new ‘circular factory’ for processing end-of-life vehicles, with a goal of being able to recycle close to 20,000 vehicles annually.

L’Oréal has entered into a partnership to turn captured carbon from its operations into packaging materials. While it’s early stages, the tie-up could help reduce its packaging footprint. 

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.