Emperor Sustainability Briefing 18.06.2026

Issue #23

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Kicking off 

Just as a certain sporting tournament is bringing together the world’s best, we have the heavyweights battling it out for top spot in this edition of the Briefing. SBTi releases its long-awaited flagship standard, disclosures platform the CDP charts a new course, and the International Organization for Standardization (ISO) publishes its transition planning approach. 

As for the World Cup – it’s hot! Both the physical impacts experienced by the players, and the widespread criticism of the environmental footprint of such a large tournament, are reminders of how ingrained climate change has become in our responses to global events. Discussions of its excess impacts transform what was once a global celebration into something of a guilty pleasure. While it’s a shame to lose some of the enjoyment, it’s always encouraging to see climate change within the public conscience. 

We hope you enjoy this Briefing, and meet some goals of your own (sorry)! 

Contents:

CDP split – GHG spat

SBTi 2.0 – TCFD for products

ISO transition plans – Italian energy

Reporting Highlight:

Schneider Electric’s 2025 Annual Report impresses with a broad perspective, and a powerful streamlining of a wide range of expertise into a clear story. We loved Schneider’s pages on its sustainability impacts across activities and sectors, reflecting the energy partner’s key role in delivering the transition.

Stories:

Regulation and frameworks

CDP receives private equity injection; splits into two entities 

The CDP, the popular and influential environmental disclosure platform for companies, has had its commercial arm taken over by Permira, a private equity firm. In turn, it has split into two separate entities: “CDP Foundation”, a non-profit broadly focused on research into frameworks and environmental disclosures, and “CDP”, which will manage the data and disclosures services which are the organisation’s stock-in-trade. In broad: a research arm, and a commercial arm. Last year CDP went through a restructuring on the back of economic challenges, with it being widely understood that Permira will be providing CDP with a cash injection as part of this new arrangement.

While it’s unclear – based on CDP’s release at least – what immediate effect this will have for CDP- reporting companies, we would think it unlikely that the organisation would significantly disrupt its core disclosure services. These are its main offering, and are ultimately appreciated most for their consistency and clarity.

In fact, the news may bode well for reporters and data users, as we could see the platform equipped with spruced-up services and new offerings. Many in corporate sustainability will hope that CDP succeeds and thrives in its new phase. 

GHG Protocol internal dispute causes delays to carbon accounting advice 

The GHG Protocol, the world’s foremost emissions accounting standard setter, published its Land Sector and Removals (LSR) Standard in January of this year. However, reporters were confused to see that accompanying carbon guidance specific to forests had still not been released five months later. It turns out now that the delay had been down to a dispute internally, as stakeholders disagreed over how removals for forestry should be accounted for. In a resignation letter, a prominent member of the standards board accused GHG Protocol of violating its own governance processes, claiming that industry pressures had unfairly skewed the approach being taken. GHG Protocol has responded and argued that there had been no “material breach of due process”. When eventual guidance is released, we may receive a clearer sense of the organisation’s direction on forestry, and evaluate the extent to which the standard has or hasn’t been bent towards corporate interests. 

The LSR Standard itself is set to take effect for accounting from January 1st 2027. Perhaps ironically, those awaiting the accompanying forestry guidance may now receive this sooner rather than later given that internal blockers – however justified they may prove to be – have now vacated. 

SBTi launches CNZS 2.0, its new flagship standard 

Companies have consistently set science-based targets in good faith, but increasingly complex supply chains have made them difficult to achieve in practice – particularly in the realm of scope 3 emissions, where progress will often depend on suppliers, policy, and the wider industry. The SBTi, the world’s leading decarbonisation target organisation, has approached this challenge head on with its much-anticipated Corporate Net Zero Standard 2.0 (CNZS 2.0). 

Its stated approach for companies has, in the broadest terms, been made more straightforward: set targets alongside implementation plans, deploy every decarbonisation lever within your control, be transparent about barriers, and disclose the actions planned to address them. Of note for reporters is a movement from a narrow target-setting focus into a standard that is a more complete disclosures task in its own right, requiring transition plans and narrative discussion of actions. 

From a pure target-setting standpoint, perhaps the biggest change to 2.0 is the greater allowance for scope 3 approaches. 

Companies exposed to certain hard-to-decarbonise activities – for instance steel production, or road vehicles – have historically found it impossible to set absolute emissions reductions targets, and were therefore excluded. In 2.0, “Tailored target-setting options” will enable scope 3 targets on, for instance, the volume of low-carbon products purchased, or the proportion of net-zero aligned products sold. If absolute emissions had previously been a blocker to SBTi validation, you may want to look again to see if one of these avenues now enables a scope 3 target. 

Compared to previously-seen draft versions of 2.0, there are no big surprises in this final version – the SBTi provides its own ‘what’s new’ roundup for the standard. To summarise: smaller companies and lower-income regions will receive accommodations, scope 1 and 2 targets now have to be separate, transition plans must be published within 15 months of target validation, and smaller emissions categories can be excluded from near-term targets. If you are wondering what this might mean for reporting and communications approaches, and what kind of transition plan content will fulfil the SBTi’s requirements, then do be in touch with us to discuss. 

Companies can set targets using 2.0 from the beginning of 2027, with version 1 of the Standard becoming invalid for submissions or renewals at the beginning of 2028. This gives a generous crossover period – but if you are currently planning to validate a target, you should be looking to use 2.0.

UK FCA proposes dropping TCFD reporting for investment products

The UK FCA currently requires asset managers to publish both an ‘entity level’ TCFD report, which covers the entity in full, as well as separate ‘product level’ reports. The ruling on product level reports mean that firms have to publish climate information for each investment product, such as a fund, and cover metrics including WACI (weighted average carbon intensity) and the carbon composition of the portfolio. 

While in a recent review the regulator was happy with the information produced for entity-level reports, it has now decided to pursue dropping product-level reporting, citing low engagement with these reports and a trend for investors going directly to firms for their data needs. 

In our view, this is likely a savvy move. Product-level TCFD reporting resulted in firms publishing reports covering sometimes thirty or more investment products, and we’re not convinced that this information was always being used. A proposal is open now, set to close in July. It is unclear how quickly any new ruling may come into effect, but we wouldn’t be too surprised to see such reports be unnecessary for FY27 reporting. 

ISO steps into the world of transition plans 

ISO has launched “ISO 32212 – Sustainable Finance: Net Zero Transition Planning for Financial Institutions”, a new standard aimed at enabling banks, insurers, and investors to develop and operationally integrate climate transition plans. The ISO provides a common framework for financial sector actors to assess their position, identify risks and opportunities, and embed objectives and targets into decisions. 

Given the popularity and success of ISOs in sustainability, particularly the environmentally-minded ISO 14000 family, this new release could be quietly influential on how transition plans are approached. While it doesn’t necessarily go directly head-to-head with disclosure systems such as the TPT, in being a system for internal integration, ISO 32212 may ultimately wield more force than the externally-focused frameworks.  

Short List:

National Grid has launched a new supplier mechanism to help it deliver off-site Biodiversity Net Gain (BNG) projects, with projects to be paired with its infrastructure developments. 

DHL is set to invest €160 Million in decarbonisation infrastructure in France by the end of 2027.

Energy 

EU approves Italian Renewable Energy Scheme 

The EU has approved a €23 billion Italian State aid scheme, under the 2025 Clean Industrial Deal State Aid Framework, to accelerate renewable electricity production. The approval gives Italy a major policy tool to expand renewable generation, reduce reliance on imported energy, and move closer to its 2030 climate and energy targets. The scheme will support new installations using onshore wind, solar, hydropower and sewage gas, with these projects together expected to add 37.15 GW of renewable electricity capacity – equivalent to roughly 48% of Italy's current renewable capacity. It also includes specific funding designed to support smaller projects and developers, including those as small as 1MW. 

This represents a strong step forward for Italy's transition to clean energy, and a clear signal of the scale of support now available to renewable developers in the market.

One Number:

1,200

The number of non EU 
companies remaining in scope of the EU’s CSRD following the EU Omnibus simplification legislation last year. This is down from 10,000 companies, according to EFRAG, the EU’s standard setter. 

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.