Global Sustainability & ESG Insights - October 2026

Global

ISSB Consults on Proposed Nature-related Disclosures Practice Statement

On October 22, the International Sustainability Standards Board (ISSB) published proposals for nature-related disclosures for consultation. The proposals take the form of a Practice Statement that would supplement IFRS S1 and IFRS S2. Entities would not be required to apply the Practice Statement to assert compliance with ISSB Standards, although jurisdictions could choose to make its application mandatory. The proposals draw extensively on the Taskforce on Nature-related Financial Disclosures (TNFD) framework. Companies would consider the location of assets and activities throughout the value chain and interactions, including engagement, with Indigenous Peoples and Local Communities. They would disclose the amount and percentage of assets or business activities vulnerable to nature-related risks and aligned with nature-related opportunities. Nature-related scenario analysis would be used to assess the resilience of an entity’s strategy and business model, using an approach commensurate with its circumstances. The ISSB is also seeking views on whether the nature-related requirements should ultimately be issued in another form, including as a Standard instead. Comments are due by February 19, 2027.

Asia

Singapore

MAS Reinforces Expectations on Banks' Management of Haze-Related Risks

On October 28, the Monetary Authority of Singapore (MAS) issued a statement on banks' management of haze-related environmental risks. MAS expects banks to identify, assess, manage and monitor material environmental risks, including pollution and deforestation. Banks should consider information released by the National Environment Agency under the Transboundary Haze Pollution Act. Where customers may be linked to activities contributing to haze, banks should engage them and obtain sufficient information to understand their role and involvement, including whether adequate measures are in place to prevent, detect and stop fires. Where heightened environmental risks are identified, banks should take appropriate mitigating measures, such as imposing conditions or reviewing financing terms. Clear breaches of environmental laws would warrant stronger measures, including limiting exposures or exiting the relationship.

Updated Standard Clarifies Use of Renewable Energy Certificates

On October 27, Enterprise Singapore, through the Singapore Standards Council, together with the Ministry of Energy, Trade and Industry and the Energy Market Authority, updated SS 673, Code of Practice for Renewable Energy Certificates (RECs). Companies use RECs to substantiate renewable electricity use for emissions reporting and sustainability targets. Under the updated standard, claims of renewable electricity usage in Singapore, including market-based Scope 2 claims, should be supported by RECs linked to renewable electricity supplied to Singapore’s power grid. These include RECs from renewable electricity generated domestically and from approved low-carbon electricity import projects. RECs from other overseas projects may still be purchased to support renewable energy development and regional decarbonization but should not be used to support claims of renewable electricity usage in Singapore.  First launched in 2021, SS 673 provides a framework for the measurement, reporting and verification of REC issuance and management and sets good practices for REC transactions and claims. The updated 2026 edition will be available for purchase from mid-November.

Digital Infrastructure Act Enacted

On October 7, the Digital Infrastructure Act was enacted. The Act establishes a licensing framework for providers of major digital infrastructure services and data center operators. The Act requires data centers in Singapore with a critical IT loan of at least 3 megawatts (MW) to be licensed. It also introduces a separate, stricter licensing regime for major colocation and cloud data centers (at least 10 MW) and major cloud service providers. The Act incorporates climate-related obligations into the digital infrastructure framework, referencing greenhouse gas emissions, eligible international carbon credits, and ministerial oversight of climate policies. Penalties for non-compliance may be up to $1 million or 10% of an operator’s Singapore turnover.

Beverage Container Return Scheme Takes Full Effect

From October 1, the requirement to display the prescribed deposit mark took effect under Singapore’s Beverage Container Return Scheme. Regulated plastic and/or metal beverage containers between 150 ml and 3 liters inclusive must carry the prescribed deposit mark. National Environment Agency’s guidance also requires a registered barcode. Certain liquids are excluded from the scheme, including special medical purpose beverages, flavorings and syrups, soups, semi-liquid foods, and medicinal and health products. A deposit of S$0.10 applies to each beverage product carrying the deposit mark. Other scheme requirements have applied since April 1, including obligations for large supermarkets to operate return points and display clear signs directing consumers to them. Return points must also meet accessibility, location and safety requirements. Breaches are strict liability offences punishable by a fine of up to S$10,000, imprisonment of up to three months, or both. Certain supplies, including specified exports and duty-free sales, are exempt from the deposit-mark requirement. Businesses relying on specified supply-chain exemptions must retain supporting records for five years and lose the exemption for any period of non-compliance.

Europe

ESMA Proposes Simpler Taxonomy Reporting

On October 29, the European Securities and Markets Authority (ESMA) published technical advice on simplifying key performance indicators (KPIs) under the Taxonomy Disclosures Delegated Act. ESMA recommends narrowing the mandatory operating expenditure KPI to non-capitalized research and development expenditure. It also proposes simplifying group-level Taxonomy reporting, including by removing the weighted-average KPI calculation, introducing targeted measures to make disclosures more proportionate, clearer and easier to use. The advice was coordinated with the other European Supervisory Authorities. The European Commission will consider the advice as part of its review of the Taxonomy Disclosures Delegated Act. 

Commission Presents EU Climate Resilience Framework and Proposed Law

On October 27, the European Commission published its EU Climate Resilience Framework, together with a proposed Regulation establishing the European Climate Resilience Law. The framework aims to enhance anticipatory climate risk management across the EU. Elements include clarifying risk ownership and embedding climate resilience in planning and decision-making. The framework also seeks to improve risk assessments, strengthen investment and provide enabling tools. The proposed Regulation would set common rules for identifying, assessing and managing climate risk. 

For more information, view our briefing. 

Parliament Adopts Position on Delaying Methane Regulation Obligations 

On October 22, the European Parliament adopted its position on the Commission’s proposal to postpone certain obligations under the EU Methane Regulation. The Commission had proposed delaying certain importer obligations and methane intensity reporting by one year, following concerns about the availability of compliant supplies amid strained energy markets and high prices. Parliament supports the postponement but has proposed a longer, three-year delay. Under Parliament’s position, importers of crude oil, natural gas and coal would have until May 31, 2031, to demonstrate compliant contracts. Contracts concluded or renewed from August 4, 2024, must cover only fuel subject to equivalent monitoring, reporting and verification. First methane intensity reporting by EU producers and importers would move from August 5, 2029, to August 5, 2031. The file now proceeds to trilogue negotiations with the Council under Parliament's urgent procedure. 

Council Agrees Position on Easing Packaging EPR Rules for Small Producers

On October 21, the Council of the EU agreed its position on a proposal to suspend certain requirements under the Packaging and Packaging Waste Regulation. The requirements require EU producers to appoint an authorized representative in each other member state where they place packaging or packaged products on the market. The proposal aims to reduce disproportionate administrative burdens on small packaging producers. Under the Council’s position, producers supplying less than 1 ton of packaging per calendar year to another member state could be exempted. A comprehensive EPR solution is expected under the forthcoming Circular Economy Act. The proposal forms part of the Omnibus VIII environmental simplification package. The Council presidency will now begin negotiations with the European Parliament.

EFRAG Consults on Sustainability Reporting Agenda for 2027–2029

On October 16, EFRAG launched a public consultation on its sustainability reporting agenda for 2027 - 2029. The consultation seeks views on EFRAG’s strategic direction, activities and priorities from mid-2027 onwards. With the core CSRD standard-setting programme expected to be largely complete following ESRS for certain non-EU undertakings, EFRAG proposes giving limited priority to further standard-setting during this period. EFRAG proposes allocating approximately half its capacity to supporting the implementation of mandatory and voluntary sustainability reporting. Potential support areas include double materiality, environmental and social metrics, EU regulatory interactions, and cybersecurity disclosures. The consultation will close on February 15, 2027, with the workplan expected in the second quarter of 2027. 

ESMA Publishes Thematic Notes on Sustainability Impact and Transition Claims

On October 12, ESMA published two thematic notes addressing impact and climate transition claims in financial markets. The notes aim to support clear, fair and non-misleading sustainability-related communications and reduce greenwashing risks. They provide practical “do’s and don’ts” and examples based on observed market practices. For impact claims, market participants should explain their objectives, how positive impact will be generated and how results will be measured. They should distinguish between investee and investor impact and substantiate claims through credible methodologies, assumptions and relevant performance indicators. The notes provide practical examples for funds and bonds, including use-of-proceeds and sustainability-linked bonds. The thematic notes do not create new regulatory requirements but clarify existing expectations for sustainability-related communications.

First Energy Audits Due Under EU Energy Efficiency Directive

By October 11, qualifying companies must complete their first energy audit under the recast Energy Efficiency Directive. The requirement applies to companies with average annual energy consumption exceeding 10 terajoules over the previous three years, taking all energy carriers together, that do not implement an energy management system. Companies with qualifying energy management systems are exempt. Audits must be carried out independently and cost-effectively by qualified or accredited experts, or implemented and supervised by independent authorities under national legislation. Subsequent audits must be conducted at least every four years. Companies must prepare action plans addressing audit recommendations that are technically or economically feasible. Action plans and implementation rates must also be published in annual reports and made publicly available, subject to confidentiality protections. Requirements apply through national measures implementing the Directive, and Member States may impose stricter requirements.

Commission Selects 46 New Critical Raw Materials Strategic Projects

On October 9, the European Commission selected 46 new Strategic Projects under the Critical Raw Materials Act. The projects span 16 EU Member States and cover extraction, processing and recycling activities across critical raw material supply chains. They include projects supporting lithium, nickel, cobalt, graphite and rare earth elements needed for batteries and other strategic technologies. Strategic Project status supports the EU's efforts to strengthen domestic capacity and reduce reliance on individual suppliers. The designation brings the total number of Strategic Projects selected under the Critical Raw Materials Act to 106.

European Parliament Approves Stricter Worker Chemical Exposure Rules

On October 6, the European Parliament approved updated EU rules protecting workers from exposure to dangerous chemicals. The rules introduce new occupational exposure limits for cobalt, inorganic cobalt compounds, polycyclic aromatic hydrocarbons, 1,4-dioxane, as well as a long-term occupational exposure limit for isoprene. These substances are used in battery productions and across the steel, aluminum, chemical, textile and rubber industries. Where exposure cannot be reduced below the applicable limits, the updated rules clarify requirements concerning personal protective equipment, including respiratory protection and regular breaks in contamination-free areas. Employers must also ensure appropriate training for workers exposed or likely to be exposed to carcinogenic, mutagenic or reprotoxic substances.

Middle East

Saudi Arabia 

National Corporate Social Responsibility Policy in Development

On October 5, Saudi Arabia’s deputy minister of the Ministry of Human Resources and Social Development confirmed that the country’s first national corporate social responsibility policy was under development. The policy is intended to strengthen cooperation between the public, private and non-profit sectors and increase the measurable impact of CSR activities. The government is also seeking to expand SME participation alongside larger companies in delivering CSR initiatives. Saudi Arabia’s national CSR platform has recorded around SAR5 billion in spending over the past three years. The policy remains under development and is expected to take approximately one to one-and-a-half years to complete.

Qatar

QFCRA Consults on Sustainability Assurance Rules

On October 7, the Qatar Financial Centre Regulatory Authority (QFCRA) issued proposals for a new sustainability assurance framework. Under the proposals, firms reporting under the QFC’s corporate sustainability reporting framework would be required to appoint an eligible sustainability assurance provider. The framework would establish eligibility and appointment requirements for providers, together with applicable assurance reporting requirements and implementation timelines. Assurance providers would be required to comply with relevant international assurance and ethics standards, including the International Standard on Sustainability Assurance 5000 and the International Ethics Standards for Sustainability Assurance. The amended rules are proposed to commence on January 1, 2027. The consultation closed November 5, 2026.

Radiation Practice Code for Nuclear Gauges and Well Logging Approved

On October 14, Qatar's Cabinet approved a draft decision of the Minister of Environment and Climate Change introducing a radiation practice code covering nuclear gauges and well logging. Prepared in cooperation with QatarEnergy and in line with International Atomic Energy Agency standards, the proposed rules aim to establish safety requirements for the possession, use, transport and storage of radioactive sources, to strengthen oversight and protect workers, the public and the environment from radiation exposure. The draft will be published for seven days of public consultation prior to legislative review.

Draft Oil and Gas NORM Decision 

On October 7, Qatar approved the Oil and Gas NORM Decision. Prepared by the Ministry of Environment and Climate Change in cooperation with QatarEnergy, the proposed guide establishes requirements, controls and responsibilities governing the possession, use, transport, storage and handling of radioactive sources. It is intended to strengthen regulatory oversight and protect workers, the public and the environment from radiation exposure risks, in line with International Atomic Energy Agency safety standards. The draft decision will be published on the Al Meezan and Sharek platforms for seven days to obtain public feedback before being referred for legislative review.

UK 

Consultation Response on Plastic Packaging Tax Published

On October 28, HM Revenue & Customs (HMRC) published its response to a consultation on certification of mechanically recycled plastic for Plastic Packaging Tax (PPT) purposes. PPT applies to finished plastic packaging manufactured in or imported into the UK that contains less than 30% recycled content, subject to the applicable registration threshold. The government intends to introduce mandatory third-party certification of mechanically recycled plastic from April 1, 2030. The measure aims to strengthen confidence in recycled-content claims, improve compliance and address unsupported or fraudulent recycled content claims. It aligns with certification for chemically recycled plastic under a mass balance approach from April 1, 2027. Businesses may choose any certification scheme that meets minimum standards set in legislation. Audits must be carried out by accredited certification bodies, which may suspend or withdraw certification. Importers must ensure certification comes from a compliant scheme and remains valid. 

Autumn Budget 2026 Sets Out Environmental Tax and Policy Measures

On October 28, a range of environmental measures were announced as part of the Autumn Budget 2026. Key measures include:

• Landfill tax: The standard rate in England and Northern Ireland will rise to £136.70 per ton from April 2027.
• Plastic packaging tax: The rate will increase to £236.56 per ton from April 1, 2027.
• Recycled plastic certification: Mandatory third-party certification for mechanically recycled plastic packaging will apply from April 1, 2030.
• Deposit return scheme: The Deposit Management Organization, rather than individual producers, will account for VAT arising in respect of unreturned deposits.
• UK CBAM: The government is consulting on expanding the mechanism to refinery products. 
• Climate change levy: Main rates for electricity and LPG will be frozen from April 1, 2028.
• Biodiversity net gain: Residential brownfield developments up to 1.5 hectares in England will be exempt.
• Energy intensive industries: Eligible businesses will be exempt from certain policy costs from April 2027.
• Data centers: A new Data Centre Covenant sets environmental and community tests for strategic data centers.

Consultation Launched on Expanding UK CBAM to Refinery Products

On October 28, HM Treasury and HMRC launched a consultation on expanding the UK Carbon Border Adjustment Mechanism (CBAM) to include refinery products. The UK CBAM will apply to certain carbon-intensive imports in the aluminum, cement, fertilizer, hydrogen, iron and steel sectors from January 1, 2027. The government intends to expand the mechanism to refinery products, such as petrol, diesel and jet fuel, subject to consultation. The consultation proposes initially covering only fuels and blending components, while excluding low carbon fuels. If refinery products are brought within scope, UK importers would need to hold evidence of origin of imported products, including evidence of the refinery of origin where actual emissions are reported. The consultation closes on January 20, 2027.  

UK CBAM Supporting Documents Published 

On October 16, HMRC published several documents in relation to the UK’s Carbon Border Adjustment Mechanism (CBAM). CBAM will impose a carbon price on certain imported goods from sectors vulnerable to carbon leakage, from 1 January 1, 2027. 

• Check the default values for the CBAM: this sets out the default emissions values for 2027-28 for goods in sectors in-scope of CBAM (aluminum, cement, fertilizer, hydrogen, iron and steel). Default values, instead of verified actual emissions data, can be used in CBAM returns.
• The CBAM (Default Values) Force of Law Notice (Draft): this draft notice sets out the default values legal effect.
• Illustrative CBAM rates and worked example for CBAM: this is intended to provide transparency on how CBAM rates are calculated, noting that the examples are based on indicative rates and actual rates will be set quarterly, with the first rates to be published before the end of this year.

Consultation on Plastic Packaging Tax

On October 6, HMRC launched a technical consultation on draft regulations and supporting documentation for introducing a mass-balance approach for chemically recycled plastic under the UK Plastic Packaging Tax (PPT) regime. The approach will be available from April 1, 2027. As PPT is designed to incentivize recycled content in plastic packaging, this consultation seeks to make it easier for businesses using chemical recycling technologies to demonstrate compliance with the regime. The proposed rules set out conditions for certification, auditing, monitoring, record keeping and attribution methodologies, alongside a reference document on calculating dual-use factors for refinery and petrochemical outputs. The consultation closes on December 21, 2026. 

Mandatory Digital Waste Tracking Introduced in England and Wales

On October 1, the UK and Welsh Governments introduced mandatory digital waste tracking requirements in England and Wales. Operators of permitted facilities receiving controlled waste must record specified information using approved software. Required information must generally enter the digital waste tracking system by the end of the second working day after the day on which the waste is received. This is the first phase of the mandatory digital waste tracking regime and applies to permitted waste receiving facilities. A later phase is expected to extend the requirements to other waste operators and enable waste movements to be tracked from the point of production through transport to the receiving facility.. The regimes include exemptions and alternative record-keeping arrangements for digitally excluded operators. Non-compliance can constitute a criminal offence, and the Environment Agency may also impose civil sanctions. Similar instruments are planned for Wales, Scotland and Northern Ireland.

Packaging EPR Reporting Deadline Passes for Large Producers

On October 1, large producers were required to report packaging data under the UK’s Extended Producer Responsibility scheme for the period from January 1 to June 30, 2026. Large producers are organizations with annual turnover of at least £2 million that handle more than 50 tons of packaging in the UK. They must report packaging data every six months and register for the scheme annually. Reporting covers relevant packaging materials and weights, alongside applicable packaging classes and types. Requirements apply across activities including branding, packing, importing, online marketplaces, hiring and supplying empty packaging. Certain producers must also report recyclability and UK nation data, depending on their packaging activities. The next reporting deadline is April 1, 2027, covering packaging data from July 1, to December 31, 2026. Small producers report annually, with their next reporting and registration deadline falling on April 1, 2027 and covering the 2026 calendar year.

US 

EPA Again Extends 2025 Greenhouse Gas Reporting Deadline

On October 14, EPA again extended the reporting year 2025 Greenhouse Gas Reporting Program deadline. Unless EPA finalizes separate changes eliminating or suspending their reporting obligations, covered US facilities, suppliers, and carbon dioxide sequestration sites  must submit by March 10, , 2027reporting-year 2025 reports. The deadline has been  extended  multiple times while the EPA considers wider changes to the program. Those proposed changes could remove reporting obligations for 46 source categories and alter requirements for parts of the petroleum and natural gas sector. The deadline extension does not change any other reporting requirements. The EPA expects to address the proposed wider changes through subsequent final actions.

EPA Proposes Further Revisions to Oil and Natural Gas Emission Standards

On October 27, the Environmental Protection Agency (EPA) proposed further revisions to its 2024 oil and natural gas standards, commonly known as OOOOb/c, under the Clean Air Act. The proposal would introduce differentiated requirements for certain well types, remove the Super Emitter Program, allow greater flexibility for flaring associated gas, and amend technical requirements for emissions-control systems. If finalized, the revisions would ease some federal emissions-control and monitoring requirements introduced in 2024. The proposal will be subject to at least a 45-day public comment period following publication in the Federal Register.

EPA Launches PFAS TECH Strategy to Advance Treatment Technologies

On October 26, the Environmental Protection Agency (EPA) launched the PFAS Technology, Evaluation, Coordination, and Harmonization (PFAS TECH) strategy. It is EPA's first agency-wide strategy to accelerate PFAS treatment and destruction technologies. It aims to accelerate research and development through funding, partnerships and support for early-stage innovation. Technologies to be tested include foam fractionation and supercritical water oxidation. Pilot projects will run at Superfund sites, military facilities, wastewater treatment plants and drinking water systems. The EPA will also issue user-friendly guidance and launch the Break the Bond Navigator. 

DOE Establishes Emissions Value Request Process for Clean Fuel Tax Credit

On October 14, the Department of Energy released the Emissions Value Request process for the Section 45Z Clean Fuel Production Credit. Transportation-fuel producers whose fuel type, feedstock or production pathway is not included in the applicable emissions-rate table can use the process to seek a lifecycle emissions value. That value can then support an application to the US Treasury for a provisional emissions rate. Applications require technical and engineering information, including material demonstrating project maturity.

EPA Delays Hazardous-Substance Facility Response Plan Requirements

On October 13, the Environmental Protection Agency finalized an extension, from June 1, 2027, to June 1, 2030, of the compliance date for Clean Water Act facility response plans covering potential worst-case discharges of hazardous substances. The requirements apply to certain onshore, non-transportation facilities that could cause substantial environmental harm through a discharge into navigable waters or adjoining shorelines. The final rule also removes references to climate change and environmental justice from the planning requirements. It takes effect on December 14, 2026.

California Corporate Climate Disclosure Regulation Takes Effect

On October 12, California’s Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation took effect following approval by the California Office of Administrative Law. The regulation implements initial requirements under SB 253, including the first reporting deadline for the state’s corporate greenhouse gas reporting regime. US-based entities doing business in California with annual revenues exceeding $1 billion are generally required to report Scope 1 and Scope 2 greenhouse gas emissions for the prior fiscal year by November 10, 2026. Scope 3 reporting is due to begin in 2027. The California Air Resources Board has also issued reporting guidance and established a voluntary intake platform to support first-year submissions.

California Recyclability Labelling Requirements Take Effect

On October 4, the compliance date arrived for new recyclability labelling restrictions under California SB 343. The restrictions apply to products and packaging manufactured after October 4, 2026. SB 343 restricts chasing arrows symbols and other recyclability claims unless specified criteria are satisfied. Products must generally be collected by programs covering at least 60% of California’s population. They must also satisfy statutory sorting and recycling criteria based on California’s recycling infrastructure. Manufacturers must assess their products against CalRecycle’s published data when determining whether recyclability claims are permitted. However, a federal court preliminary injunction currently blocks enforcement of SB 343 while litigation continues.

Co-authored by Nathan Handoll (ESG Researcher in Knowledge).

Further reading 

• China-climate-disclosure-implementation-framework-takes-shape
• EU: Empowering Consumers for the Green Transition Directive
• Green claims under scrutiny in EU consumer law - part 2
• Commercially Connected - October 2026
• China: Update on counter sanctions and their impact on multinationals
• COP31: Opening day puts health and heat risk in focus