Emperor Sustainability Briefing 20.11.2025

Issue #9

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Tying up neatly 

If it weren’t mid-November this Briefing might have been an ideal cap to 2025, with some of the year’s major stories finding resolutions. The Omnibus reductions have finally passed through Parliament, the TNFD has announced its conclusion, and the SBTi’s new standard has its second version out. Sometimes, you have a two-week period where… slightly more than two weeks happens all at once. 

Also of note is an absence of a COP30 story. Nothing has quite met the threshold for a Briefing update yet, but we’ll hope to bring you something on its conclusions in the next edition. 

In this Briefing

Omnibus passes parliament – SBTi’s 2.0

TNFD to conclude – UK assurance standard

Aviation claims – Red states warning

Materiality fines

Regulation and frameworks

European Parliament votes to adopt enhanced Omnibus proposal 

Following a failed first vote, the European Parliament has now successfully voted to adopt a position on the EU Omnibus – its policy raft of sustainability regulation rollbacks – which weakens the regulation even more than the original proposal. The vote’s success this time was a consequence of the European People’s Party (EPP) turning to further-right parties in order to form a negotiating position – which helps explain the strength of the stance. The Omnibus will now have to pass through the legislative process ahead of the amendments truly coming into force, but this news can be said to signify the passing of a major hurdle, with some EU policy voices lamenting that the decision “drives a stake through the heart of Europe’s wider sustainability agenda.” 

CSRD thresholds are set to be expanded to companies with over 1,750 employees and €450m net turnover, compared to the original Omnibus proposal of 1,000 employees. For non-EU companies with EU subsidiaries, the turnover threshold becomes €450m turnover generated in the EU. For CSDDD, the scope has narrowed to only extremely large companies – with more than 5,000 employees and a net worldwide turnover of more than €1.5bn. There are further amendments, beyond these scope changes, to both directives.

While you may have undertaken an initial re-scoping exercise for your company following the first Omnibus announcement, as this new, narrower scope has now been all but confirmed it’s now worth undertaking a follow-up review with your legal team to see if you’ve fallen out of scope. Once you have clarity and need to understand what your reporting strategy looks like from here, be in touch with Emperor and we can help you decide your next steps. 

SBTi releases second draft of second standard 

As the next stage in the long finalisation of SBTi’s Corporate Net Zero Standard (CNZS) 2.0, the target standard setter has released – with many important revisions – its second draft of 2.0 for public consultation. This consultation will run to December 9th, and after further reviews a final standard will be published in 2026 – although CNZS 2.0 won’t be mandatory until 2028. 

SBTi has been busy this past half-year, based on the amount that’s new or changed in this latest version – with a useful overall summary provided by the SBTi here. 

A revised structure provides a welcome streamlining to the document and clears up some terminological challenges. Scope 1 and 2 require different targets (a change introduced in the first 2.0 draft), with Scope 1 now having 3 approaches for target setting including one related to technological development pathways for asset decarbonisation – particularly interesting for hard-to-abate sectors. Long-term scope 2 targets are now not required for ‘Category B’ companies (SBTi’s less stringent category). And the revisions to scope 3 are now refocused to just high-priority categories for near-term targets, a useful simplification. 

Importantly, it is now confirmed that Category A companies (SBTi’s more stringent category) will be required to disclose a transition plan within 12 months of initial validation. 

We would note that this second version is quite different to the first and introduces quite a few new elements – so we don’t recommend that companies begin their calculations just yet, until we have a more final version. Additionally, it’s clearer than ever that CNZS 2.0 will make target setting more complex overall for companies rather than less, meaning we still expect most companies to undertake their SBTi work alongside consultancy support. If you’d like to talk over what the new standard might mean for you, we can set up a discussion to provide some guidance. 

TNFD to conclude work; standards to be absorbed by ISSB 

In 2023 the TCFD ceased operations, with its guidance being subsumed into the ISSB’s S2 climate standard. In a comparable move, the TNFD has now announced it is set to conclude its work in 2026, with the ISSB taking forward its nature related standards as part of its own standards sets. TNFD’s press release implies this will eventually be as an add-on to the S1 standard, covering non-climate sustainability matters, rather than as a new standard (for instance an ‘S3’), but this is still to be determined. The move is a sensible rationalisation, and ultimately bodes well for nature reporting. With the world’s economies gradually uptaking the IFRS sustainability standards (i.e. the ISSB standards), by becoming a part of these the TNFD’s recommendations will receive more visibility and stand a better chance of being mandated for companies. We recommend that companies underway with TNFD still report using this standard for now. On our part, we’ve seen an increased trend towards combined nature and climate reporting – which the TNFD framework’s absorption into ISSB also points in the direction of. The IFRS has made clear it will use the standard as a basis, and going by precedent, the core of the framework will not fundamentally change during incorporation. 

UK’s FRC releases Sustainability Reporting Assurance Standard 

The UK’s Financial Reporting Council (FRC) has introduced its International Standard on Sustainability Assurance (UK) 5000, or ISSA (UK) 5000 – another acronym for your list! It’s based on the global benchmark developed by the International Auditing and Assurance Standards Board (IAASB), and designed to help assure sustainability information required by a multitude of frameworks – including ESRS, the ISSB standards, GRI, and ISO. 

ISSA aims to build greater quality and consistency in assurance engagements for sustainability reporting, and coincides with the incoming UK SRS sustainability standards, as well as a voluntary registration regime for assurance providers. ISSA will be voluntary, but as it is the standard being introduced by the FRC – a central body – it will be expected to set a wider benchmark for credibility. 

Sustainability reporting assurance, particularly in the UK, is in relatively early stages of development. The ‘Big Four’ audit firms have a good deal of control over the sustainability assurance market, with their share being around 40% of the FTSE350. One of the goals of ISSA and the ongoing consultation on assurance is to drive competition in the market, not least to help address some of the horror stories we’ve heard around sky-high assurance costs for sustainability metrics. Whatever the immediate consequences, assurance is an essential part of the overall long-term sustainability picture for companies, and any company with a moderate-to-large data gathering process in place for ESG metrics should keep a close eye on market developments. 

Corporate

Greenwashing investigation finds airlines’ environmental claims misleading  

A group of over 20 airlines, including Air France and RyanAir, have reached an agreement with the European Commission to alter some of their environmental claims. This follows a 2023 complaint by the European Consumer Organisation (BEUC) and an investigation identifying practices such as implying that paying extra fees or using sustainable aviation fuel (SAF) could neutralise flight emissions.

Each airline will have to stop claiming that the CO2 emissions of a specific flight could be neutralised, offset, or directly reduced by consumer financial contributions to climate protection projects or alternative aviation fuels. The airlines will also require more evidence and clarity before they are allowed to use the term ‘sustainable aviation fuel’ (SAF), which is still very much part of the EU’s decarbonisation plans after the EU pledged to mobilise at least €2.9 billion in investments in SAF by the end of 2027. 

Red states warn major US companies against EU sustainability compliance 

A coalition of 16 US state attorneys general, led by Florida, have warned companies against adhering to the EU’s CSRD and CSDDD sustainability regulations in a series of letters to CEOs. The targeted companies, including Microsoft, Google, and Meta, are warned of legal ramifications in the case of compliance – the latest in a series of US shots against ESG this year which, while showy, also speak to real potential risks. Earlier this year, we heard about an EU carve-out for the US on these frameworks. If you’re a US company assessing its exposure to CSRD or CSDDD, please see the Omnibus story in this Briefing ahead of judging what the scale of your compliance might look like. 

Spanish bank fined nearly €200k over materiality assessment

The European Central Bank (ECB) has issued its first-ever fine against a bank for failing to identify climate risks through a materiality assessment process, with Spanish Abanca being subject to a €187,650 wrist-slap. The reprimand follows an initial warning issued by the ECB to 20 banks in 2023 over inadequate materiality processes, which the other banks largely met – showing it pays to do your sustainability homework! 

One Number

75%

Of C-suite execs globally now cite sustainability as a top priority, according to Reuters, up 6% from six months ago

Short list

Sky has unveiled a new hydrogen-powered mobile power unit, for film and TV production sets, with the goal of replacing diesel generators which remain common across the industry

Forbion has raised €200m for its new biology-based industrial sustainability solutions fund

Heineken is set to install a new heat battery to help decarbonise a brewery near Lisbon, in partnership with EDP and Rondo Energy

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.