Global Sustainability & ESG Insights - April 2025

Global

ISSB publishes Exposure Draft proposing amendments to IFRS S2

On April 28, the International Sustainability Standards Board (ISSB) published an Exposure Draft proposing amendments to IFRS S2 to ease the application of climate-related disclosure requirements. The amendments aim to provide relief for measuring and disclosing certain GHG emissions, including Scope 3 Category 15 emissions and the use of alternative measurement methods. These changes are designed to support companies in applying the standards without reducing the usefulness of the information provided to investors. The draft is open for comment until June 27, 2025.

Summit on the Future of Energy Security

On April 25, the Summit on the Future of Energy Security concluded, which was held in London and co-hosted by the International Energy Association and the UK Government. The Summit gathered leaders from 60 governments and 50 major energy companies. Key discussions included enhanced international cooperation, holistic energy security encompassing cybersecurity and clean technologies, and energy affordability and access. The UK announced a £300 million boost for offshore wind and a major carbon capture deal. Emphasis is placed on responsible resource management, technology and innovation, and strategic grid expansion to support clean energy transitions.

IMO reveals net-zero regulations for global shipping

On April 11, the International Maritime Organization (IMO) approved draft regulations for a net-zero emissions framework for global shipping, with the aim of achieving net-zero emissions by or around 2050. The framework includes mandatory emissions limits and greenhouse gas pricing, with a new fuel standard for ships and a global pricing mechanism for emissions. The measures, set to be adopted in October 2025, will be mandatory for large ocean-going ships over 5,000 gross tonnage, starting in 2027. The IMO Net-Zero Fund will support low-emission ships, innovation, and just transition initiatives in developing countries, while mitigating impacts on vulnerable states.

IFRS Foundation and TNFD formalize collaboration on nature-related information

On April 9, the IFRS Foundation and the Taskforce on Nature-related Financial Disclosures (TNFD) signed an agreement to enhance nature-related financial disclosures for capital markets. This collaboration aims to integrate TNFD recommendations into the International Sustainability Standards Board (ISSB) work, improving transparency and accountability. The partnership will support the ISSB's Biodiversity, Ecosystems, and Ecosystem Services research project and strengthen global sustainability reporting standards.

Report calls for eradication of modern slavery and human trafficking by 2030

On April 8, the Global Commission on Modern Slavery and Human Trafficking published a report urging action to eradicate modern slavery by 2030. The report highlights systemic failures in existing legislation and business practices, which have left 50 million people trapped in slavery. It calls for stronger supply chain accountability, import restrictions, and extended transparency laws. Recommendations include the establishment of robust legislative frameworks, better enforcement, survivor support, and the integration of anti-slavery efforts in humanitarian responses.

Asia

China: Environmental progress in 2024

On April 27, a press release was published by the PRC State Council, outlining progress made in improving its ecological environment in 2024. Key achievements include:

• air quality: 87.2% of days had good air quality, a 1.7% increase from 2023 and heavily polluted days decreased to 0.9%

• water quality: surface water quality improved, while groundwater and seawater quality remained stable

• soil pollution: heavy metal levels at key sites showed a declining trend, with soil deterioration preliminarily controlled

All environmental targets for 2024 were met, surpassing the goals set in the 14th Five-Year Plan. For 2025, efforts will focus on further reducing PM (particulate matter) 2.5 levels and increasing the proportion of good air quality days.

Hong Kong: Approval for more hydrogen fuel projects

On April 25, the Environment & Ecology Bureau (EEB) approved eight new hydrogen fuel technology trial projects. These include hydrogen fuel cell (HFC) goods vehicles for cross-boundary transport, HFC coaches for local and cross-boundary passenger services, and hydrogen power generation for electric vehicle charging. The EEB also briefed the working group on the progress of Hong Kong's hydrogen development strategy, including safety regulations and upcoming symposiums.

China: National carbon emissions trading market in 2025

On April 15, Ministry of Ecology and Environment published a circular on effectively advancing the work relating to the national carbon emissions trading market in 2025. It focusses on key emitting enterprises in power generation, steel, cement, and aluminum smelting industries. It includes requirements for formulating and publishing lists of key emitters, managing carbon emission data quality, allocating and settling carbon emission allowances, and strengthening organizational leadership, capacity building, and oversight. Provincial-level authorities should list entities within their regions for the years 2024, 2025, and 2026. After identification, key emitting enterprises will be included in the management of the national carbon emission trading market and will no longer participate in the local carbon emission trading market, avoiding duplicate control.

Hong Kong:  Ozone Layer Protection (Amendment) Bill 2024

On April 11, the Ozone Layer Protection (Amendment) Bill 2024 was published in the Gazette. It aims to implement the Kigali Amendment to the Montreal Protocol, enhancing controls on hydrofluorocarbons (HFCs) with high global warming potential. It introduces regulations for the safe handling of hazardous refrigerants and empowers the Secretary for Environment and Ecology to make related regulations.

Hong Kong:  Promotion of Recycling and Proper Disposal of Products (Miscellaneous Amendments) Bill 2025

On April 11, the Hong Kong Promotion of Recycling and Proper Disposal of Products (Miscellaneous Amendments) Bill 2025 underwent House Committee consideration. The Bill aims to establish a common legislative framework for Producer Responsibility Schemes. This framework will apply to various products, facilitating the progressive inclusion of regulated products in the future. The bill is based on the principles of polluter pays ensuring that stakeholders across the value chain, from manufacturers to consumers, share responsibility for reducing waste and enhancing recycling efforts.

Hong Kong: Employment (Amendment) Ordinance 2025

On April 11, the Employment (Amendment) Ordinance 2025 was published. The Proposal sets to revise the working hours threshold for the "continuous contract" requirement under the Employment Ordinance. Also, it will lower the weekly working hours threshold from 18 to 17 hours and allow the aggregate working hours over four weeks to count towards continuous employment if they reach 68 hours.

China: Plan for management of ozone-depleting substances

On April 9, five departments, including the Ministry of Ecology and Environment published the National Plan for China's Compliance with the Montreal Protocol on Substances that Deplete the Ozone Layer (2025-2030). The plan aims to strengthen control and management of production, use, maintenance, and trade of controlled substances. It sets out the following targets:

• prohibit the controlled production and use of phased-out ozone-depleting substances and ensure sustainable compliance

• reduce hydrochlorofluorocarbon production and controlled use by 97.5% of the baseline value in 2030

Europe

EU: EBA  publishes  key indicators on climate risk in the EU/EEA banking sector

On April 25, the European Banking Authority (EBA) published an ESG dashboard to monitor broader ESG risks and provide centralized access to climate risk indicators. It benchmarks and enhances the assessment of climate-related risks across the EU/EEA banking sector, based on banks' Pillar 3 ESG disclosures. The dashboard includes indicators for real estate lending energy efficiency, showing half of EU real estate loans are below 200 kWh/m². It also tracks banks' alignment with the EU Taxonomy and green lending criteria beyond the EU Taxonomy.

EU: EFRAG work plan for revising European Sustainability Reporting Standards

On April 25, the EFRAG (European Financial Reporting Advisory Group) published its work plan for revising the first set of European Sustainability Reporting Standards (ESRS). The plan includes gathering evidence, public consultation on exposure drafts, and simplifying the ESRS. The goal is to meet the European Commission's deadline of October 31, 2025, for technical advice on the proposed delegated act to simplify EU sustainability obligations.

EU: Commission adopts proposal to protect biodiversity in the High Seas

On 24 April, the European Commission adopted a proposal for a Directive to integrate into EU law the Biodiversity Beyond National Jurisdiction' (BBNJ) Agreement. This aims to protect 30% of international waters by 2030. BBNJ, adopted by the UN in June 2023, requires ratification by 60 states to enter into force. The EU is committed to ratifying it before the UN Ocean Conference, in Nice in June 2025. The Directive includes establishing marine protected areas, conducting environmental impact assessments, and facilitating the sharing of marine genetic resources.

EU: Ecodesign for Sustainable Products Regulation

On April 16, the European Commission adopted a plan to boost circular and efficient products. The EC's 2025-2030 plan for the Ecodesign for Sustainable Products Regulation prioritizes products like steel, textiles, and furniture for ecodesign and energy labelling. Next steps include setting requirements via delegated acts and involving stakeholders. In relation to some energy-related products, ongoing work under the Ecodesign Directive should continue, and relevant requirements will be adopted not later than December 31, 2026. This initiative aims to enhance product sustainability, reduce administrative burdens, and boost EU business competitiveness. 

EU: Commission consults on Industrial Decarbonization Accelerator Act

On  April 16, the European Commission launched a public consultation and call for evidence for the Industrial Decarbonization Accelerator Act. This initiative, part of the 2025 work program, aims to simplify legislation for energy-intensive industries to decarbonize while maintaining competitiveness. The consultation runs until July 9, 2025, with the Act's adoption expected in Q4 2025. The Act aims to streamline permit granting, authorizations, and reporting requirements to facilitate investment in the EU.

EU: Commission consults on Deforestation Regulation

On April 15, the European Commission published a consultation on a proposal for a delegated regulation to clarify the scope of the EU Deforestation-free Products Regulation (EUDR). The EUDR comes into force for medium and large sized companies on December 30, 2025. It prohibits placing certain commodities on the EU market unless they are deforestation-free and legally produced. The consultation closes on May 13, 2025.

The Commission also published updated guidance and frequently asked questions on EUDR. This aims to simplify and clarify due diligence processes for companies, including annual submissions and reuse of existing statements.

EU: 'Stop-the-clock' Directive

On April 14, the European Council approved the 'Stop-the-clock' Directive. This forms part of the ‘Omnibus I’ package adopted by the European Commission at the end of February 2025. It delays the application of certain corporate sustainability reporting and due diligence requirements under the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. The aim is to boost EU competitiveness and provide legal certainty to businesses. On April 16, the Directive was published in the Official journal. Member states must transpose it by December 31, 2025.

EU: Regulation on Toy Safety

On April 11, the European Commission agreed on new toy safety rules  under the proposed Regulation on Toy Safety. The proposal will ban harmful chemicals like PFAS and endocrine disruptors. All toys will also have a Digital Product Passport to ensure safety and compliance, especially for online sales. Inspectors will have greater powers to remove dangerous toys from the market. The regulation aims to protect consumers and create fair competition for EU manufacturers.

EU: Soil Monitoring and Resilience Directive

On April 10, the European Parliament and the Council reached a provisional agreement on the Soil Monitoring and Resilience Directive. This proposal aims to improve soil health across the EU by:

• monitoring soil health with flexible criteria
• supporting soil managers to enhance soil resilience
• managing contaminated sites to protect human health and the environment
• mitigating impacts of land take on soil's ecosystem services

EU: Regulation to regulate and prevent microplastic pollution from plastic pellets

On April 9, the European Commission reached a provisional agreement on the Regulation to regulate and prevent microplastic pollution from plastic pellets. The agreement aims to reduce plastic pellet losses by up to 74%, which will benefit ecosystems and biodiversity. Certification obligations will be limited to companies handling over 1,500 tons of pellets annually, while smaller companies will receive lighter requirements and special assistance. Additionally, the agreement includes best handling measures for economic operators to prevent, contain, and clean up pellet losses.

EU: Council agrees position on new rules for cross-border enforcement in food chain

On April 7, the European Council agreed its position on new rules for cross-border enforcement in agrifood supply chain. Key elements include the improvement of transnational cooperation in cases where suppliers and buyers are in different Member States and introducing a mechanism for coordinated action in cases of large-scale cross-border unfair trading practices involving at least three EU countries. Negotiations with the European Parliament will start when the European Parliament has reached its position.

EU: Commission seeks industry input on critical raw materials recycling

On April 1, the European Commission launched a consultation to promote industry cooperation in procuring and recycling critical raw materials, in line with EU competition rules. This initiative, part of the Clean Industrial Deal Communication, seeks feedback from market participants on challenges and collaboration opportunities in sourcing, processing, recycling, and re-using critical raw materials. The focus is on 14 critical raw materials essential for sectors like renewable energy and aerospace. Stakeholders can submit their contributions by May 31, 2025.

EU: Regulation setting CO2 emission performance standards for new cars and vans

On April 1, the European Commission proposed a targeted amendment to CO2 emission standards for new cars and vans, introducing flexibility for manufacturers between 2025 and 2027. This measure allows compliance to be assessed over a three-year period, helping manufacturers balance annual emissions and invest in clean transitions. The proposal is part of the Industrial Action Plan for the automotive sector, aiming to maintain competitiveness while achieving climate goals.

Middle East

Qatar: Central Bank issues sustainable finance framework

On April 20, Qatar Central Bank launched the Sustainable Finance Framework to align with national strategies and promote growth through ESG principles. Key elements include enhancing transparency, revenue management, reporting, and external auditing. The framework aims to open new opportunities for growth and innovation by incorporating sustainable Islamic financial instruments. It supports the transition to a flexible and inclusive economy, balancing economic growth with environmental and social responsibility. Financial institutions and stakeholders in Qatar are obligated to adhere to these principles, encouraging sustainable practices and development of financial products meeting environmental and social criteria.

UK

UK: Consultation on amending Carbon Capture Revenue Support Regulations 2024

On April 28, the Department for Energy Security and Net Zero launched a consultation on amending the Carbon Capture Revenue Support Regulations 2024. The consultation covers four areas:

• directions for contracting with eligible carbon capture entities

• publication of information

• counterparties' ability to fulfill statutory functions

• eligibility criteria for carbon capture projects

The consultation will end June 9, 2025.

UK: Consultation on revised draft National Policy Statements for energy infrastructure

On April 24, the Department for Energy Security and Net Zero launched a consultation on revised energy national policy statements for major infrastructure. Updates include:

• making Clean Power 2030 the primary policy in EN-1
• prioritizing projects under this policy

• adding a section on onshore wind impacts in EN-3

• proposing inter-array wake effect assessments

Changes also support the expanding of electricity networks. The consultation will end May 29, 2025.

UK: Call for evidence on review of nuclear framework and regulation

On April 23, the Department for Energy Security and Net Zero published a call for evidence on the review of the nuclear framework and regulation. The review, conducted by the Nuclear Regulatory Taskforce, covers civil and defense nuclear regulation, including health and safety, environmental, planning, and energy transmission. It seeks input on challenges, benefits, proportionality of current requirements, and support for innovative nuclear technologies. The call for evidence will run until May 19, 2025.

UK: Consultation on voluntary carbon and nature markets

On April 17, the Department for Energy Security and Net Zero launched a consultation on the implementation of the UK government’s principles for voluntary carbon and nature market integrity. It seeks views on six principles for high-integrity credits, aiming to guide businesses in using carbon credits effectively. The consultation addresses the use of carbon credits to offset Scope 3 emissions, emphasizing the need for climate actions within value chains. The consultation will end July 10, 2025.

UK: Inquiry into PFAS risks

On April 11, the Environmental Audit Committee of the UK Parliament launched an inquiry seeking evidence into perfluoroalkyl and polyfluoroalkyl substances (PFAS). It will consider whether enough is being done to address the risks of PFAS and whether institutions are equipped to detect and monitor their impact. It will also explore what regulatory mechanisms are in place across the UK and how they compare to other jurisdictions, such as the EU and US. The inquiry will end May 26, 2025.

UK: Government publishes response to planned 2030 Ban on New Petrol and Diesel Cars

On April 7, the Department for Transport published the government response to its consultation on delivering the commitment to end the sale of new cars powered solely by internal combustion engines (ICE) by 2030 and supporting the UK's transition to zero emissions vehicles (ZEVs). The response confirms the 2030 ban on sales of new purely ICE cars, while allowing sales of hybrid and plug-in hybrid vehicles until 2035. It also includes changes to the ZEV mandate to facilitate industry upgrades to electric vehicles.

UK:  Equality (Race and Disability) Bill

On April 7, the Office for Equality and Opportunity (OEO) initiated a call for evidence regarding equality laws. This comprehensive call covers areas not previously included in the Race and Disability Bill, practical applications of current laws, and aspects of the Employment Rights Bill. The OEO seeks input on:

• race and disability pay discrimination prevalence
• effective equal pay for ethnic minorities and disabled individuals
• preventing outsourcing to avoid equal pay
• enforcing equal pay rights through a dedicated unit with trade union involvement
• enhancing pay transparency
• strengthening protection against combined discrimination
• ensuring compliance with the Public Sector Equality Duty
• creating harassment-free workplaces

The call for evidence will run until June 30, 2025.

UK: Neonatal Care (Leave and Pay Act) 2023

On April 6, statutory neonatal care leave and pay came into effect under the Neonatal Care (Leave and Pay Act) 2023. This legislation provides additional support to employees whose babies need neonatal care. Key points include:

• day one right for parents, partners, intended parents, adopters, and their partners
• up to 12 weeks leave, based on the baby's neonatal care
• notice requirements are divided into 'tier 1' and 'tier 2' with different periods
• employees are protected from detriment or dismissal for taking neonatal care leave
• eligible employees are entitled to statutory neonatal care pay

UK: Digital Markets Competition and Consumers Act 2024

On April 6, the Digital Markets Competition and Consumers Act 2024 came into force. It sets out to enhance the Competition and Markets Authority's (CMA) powers to tackle greenwashing. The CMA will focus on enforcing against aggressive sales practices, false information, and unfair contract terms. Businesses must ensure compliance with green claims to avoid penalties, as the CMA emphasizes transparency and accountability in ESG aspects.

UK: Environment Act 2021 (Commencement No 10) Regulations 2025

On April 3, the Environment Act 2021 (Commencement No 10) Regulations 2025, were published, becoming effective on May 1, 2025. These Commencements mandate biodiversity net gain (BNG) for Crown land development. These regulations implement Schedule 7A of the Town and Country Planning Act 1990, requiring new planning permissions to include BNG conditions. This means developers must ensure that their projects result in a measurable increase in biodiversity.

US

US: Energy Secretary marks 100 days energy policy under President Trump

On April 29, Secretary of Energy Chris Wright released a statement marking President Trump’s 100th day in office. The statement highlights energy policy announcements from January 21 to April 28, with links to further information.

US: EPA outlines action to combat PFAS contamination

On April 28, the Environmental Protection Agency (EPA) outlined how it plans  to address Polyfluoroalkyl Substances (PFAS). According to the announcement, the plan will  include the following future actions:

• designation of an agency lead for PFAS

• creation of wastewater effluent limitations

• establishing a “polluter pays” liability framework

• development or refinement of PFAS testing strategies and air emissions measurement techniques

• coordination of compliance efforts under various environmental laws

• building partnerships for remediation and cleanup efforts

US: Move to ban petroleum-based food dyes from food chain

On April 22, the Food and Drug Administration (FDA) announced plans to phase out all petroleum-based synthetic dyes from the food supply chain. The FDA plans to fast-track the approval of natural alternatives. It wants to bring in a federal ban on some dyes, including FD&C Red No. 40 and FD&C Yellow No. 5, by the end of 2026. A single federal directive is likely to be preferable to a patchwork of differing state regulations.

US: Public hearing on proposed heat injury and illness prevention rule

On April 16, the Occupational Safety and Health Administration (OSHA) announced that it will hold a virtual public hearing on June 16, 2025 on its proposed rulemaking for Heat Injury and Illness Prevention in Outdoor and Indoor and Work Settings. The Rule was published in the Federal Register on August 30, 2024. It would require private employers to have an injury and illness prevention plan to control heat hazards. This includes requirements for drinking water, rest breaks and control of indoor heat.

US: Exemption to coal power providers from Mercury and Air Toxics Standards

On April 8, President Trump granted a two-year exemption to a number of coal power providers from the Mercury and Air Toxics Standards, delaying enforcement until 2027. The stated purposes of the exemptions are to prevent premature shutdowns of coal plants, protect jobs, and maintain energy stability.

Co-authored by  Westley Trimble and Nathan Handoll (Knowledge).

Further reading and listening

• UK’s New Trade Sanctions Against Russia 
• Commercially Connected - April 2025 
• Global – Financial services, US tariffs and retaliatory tariffs 
• Dealing with the impact of tariffs on your supply chain 
• Getting Hydrogen “Off the Grid” 
• LMA, APLMA and LSTA release revised sustainable finance principles 
• FWS and NOAA propose to narrow reach of Endangered Species Act