Emperor Sustainability Briefing 24.09.2026

Issue #30

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Green shoots 

We’re happy to bring you some stories in this edition which – whisper it – are small causes for optimism. The EU’s flagship carbon border mechanism is set to expand, sustainable investments outperform traditional counterparts by a solid margin, and a European climate insurance alliance may well be emerging.

Additionally, UK PM Andy Burnham announces £30m for “People’s Power projects” – i.e. local clean energy. Good news in its own right, the letter might also provide some insights as to his priorities.

Finally, we held our ‘UK SRS: The Inside Track’ event yesterday, diving into the UK’s new sustainability regime. If you’d like a copy of our research output document, scroll down for details…

Stories:

Regulation and frameworks

EU votes to expand CBAM by hundreds of products

The number of products included in the EU’s carbon border mechanism looks set to expand by the hundreds, after the passage of an EU Parliament vote. The Carbon Border Adjustment Mechanism (CBAM) currently targets basic materials, including aluminium and cement. It aims to prevent ‘carbon leakage’ by imposing a tax on importing such materials produced outside the EU in regions with less stringent environmental standards, effectively encouraging purchases to be made within the EU. 450 products with a high carbon leakage risk, including machinery, vehicle components and domestic appliances, are on Parliament’s list for inclusion. The Commission’s product list contains 180, so it’s likely we’ll settle somewhere in the middle, but either way the extent of this important border mechanism is set to grow.

The UK’s own CBAM is set to launch on the 1st January 2027, and broadly follows the EU in covering aluminium, cement, fertiliser, hydrogen, iron and steel.

EU to launch climate insurance alliance

European Commission President Ursula von der Leyen has announced a climate insurance alliance to increase cover within the EU bloc for extreme weather events. According to its own figures, only a quarter of the EU’s climate-related economic losses are insured, with a new scheme targeting insurers, investors, risk modellers and more to increase insurance uptake. It joins a “climate resilience” strategy pledged for October, a “heatwave plan” and an “EU water plan” as initiatives now underway. As we reported in last edition, Spain is also pushing for an EU-wide adaptation fund. 

While the summer’s heatwaves were punishing for the entire continent, there’s perhaps a silver lining to be found in the strength of response seen. Alliances such as this one often benefit from a flagship event to galvanise support, which 40C heat may have provided. 

OUT NOW: UK SRS: The Inside Track 

Your guidance document on the incoming UK Sustainability Reporting Standards (SRS), ‘UK SRS: The Inside Track’ seeks to address some of the ‘hard questions’ around SRS alignment – featuring details on financial assessment, auditors, internal alignment, and more.

Produced alongside external advisory and furnished with IFRS-sourced investor feedback, we think you’ll find it a valuable resource. If you’d like a copy, please email [email protected] and we’ll share it across. 

Short List:

FedEx has signed a deal to procure over 20 million gallons of sustainable aviation fuel (SAF) for use through 2027. The logistics company has a goal of sourcing 30% of jet fuel from alternative sources by 2030.

Sanofi joins other pharmaceutical companies in the Clean Heat Program, designed to help companies reduce their industrial heat process-related emissions. AstraZeneca joined last year.

Policy

US SEC moves to scrap shareholder proposals

Shareholder proposals in the US have long been an avenue for placing ESG pressure on companies. Through submitting a proposal to be voted on by other shareholders, activist groups could force Board and management teams to pay attention or respond to a request – for instance, asking the company to measure its emissions, or report on its strategy for net zero. Now, the SEC is proposing to repeal important rules around shareholder proposals altogether.

While the number of ESG-related proposals has been dwindling for years (as has been mentioned in previous Briefings, this was more of a 2021 / 22 thing!) it’s hard not to read this as the latest in the US’ long line of attacks on ESG, which have intensified during the Trump administration. Chris Atkins, current SEC chair, had previously indicated that eliminating the rule would be a way to “de-politicize shareholder meetings”. While states will be able to put their own laws in place on proposals, it would be a shame – but perhaps not a surprise – to see an important avenue for engagement to be cut from the overall US environment.

Andy Burnham writes to the Guardian (and covers climate change!)

In a Guardian letter very much focused on the UK’s new People’s Power projects, which provides £30m for initiatives like local solar power, Prime Minister Andy Burnham gave further insight into his stance on net zero. Writing that he was still “determined” to reach net zero by 2050, and that the transition would be an opportunity to “reindustrialise” Britain, his outlined position is one where “regulation” will explicitly not be the primary driver. This is broadly in line with the current government’s focus on devolution, with control being ‘returned’ to localities rather than arriving top-down. It’s unclear if that stance will extend into how companies will be affected by sustainability-related regulations, or if it just means that we can expect more funding for local green energy and community-based projects. But it does reiterate the point that Mr. Burnham is unlikely to instate sustainability initiatives at the expense of small business, local operators, or increases in the cost of living, which could be said to be greater political priorities.

Corporate

Ineos races ahead in EU on CO2 storage; UK operations struggle 

British conglomerate Ineos has had an up-and-down month – for once, to do with its involvement in the energy transition, rather than its stake in Manchester United football club. On a positive note, it celebrated the opening of Project Greensand in the Danish North Sea, the EU’s first full-scale facility for the permanent storage of CO2. Greensand involves injecting captured CO2, primarily originating from Danish biomethane plants, into a depleted oil field underneath the seabed for long-term storage. While the solution isn’t widely used yet, the first-of-its-kind project is an exciting one, and will hope to prove that undersea storage is a practical reality for the energy sector. 

On a more mixed note, Ineos also paused production at three plants in Hull, blaming high UK gas prices. The disruption is ultimately down to the conflict in Iran, but Ineos CEO Sir Jim Ratcliffe has been vocally critical of the government’s energy policy, accusing it of “economic vandalism”.

Together, the stories paint a mixed view. On the one hand, businesses scaling-up adventurous solutions which will be essential for a low-carbon future, on the other, having to deal with the reality of the current energy system – which remains volatile to fossil fuel pricing shocks. Ineos will be far from the only UK company balancing the impact of high gas prices with its long-term ambitions on net zero. 

One Number:

$4.2tn

Sustainable investment funds grew to a global total of $4.2 trillion in the first half of 2026, according to a Morgan Stanley report – outperforming their traditional fund peers by nearly 1% in the period. Since 2018, sustainable funds have returned 71% cumulatively, against 59% for traditional funds.

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.