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Sustainability update

November 2025

Feature story

European Parliament to enter negotiations with Council on Omnibus proposal amending sustainability reporting and due diligence rules

Yesterday, the European Parliament’s (EP) adopted its negotiating position on the Omnibus proposal with 382 votes in favour, 249 votes against and 13 abstentions. The EP will start the negotiations with the Council on 18 November, still aiming to reach a final agreement by the end of 2025.

We are sharing below a quick overview of the adopted amendments (this is not an exhaustive overview).

Corporate Sustainability Reporting Directive (CSRD):

  • Scope: undertakings exceeding the average number of 1750 employees and EUR 450 million net turnover
  • Non-EU companies with a subsidiary within the EU exceeding EUR 450 million net turnover in the preceding financial year (FY) or a branch generating EUR 450million net turnover (only if no subsidiary)
  • European Commission (EC) shall adopt a voluntary reporting standard based on its recommendation on VSME issued in July
  • EC shall adopt an assurance standard no later than 1 October 2026
  • EC shall adopt voluntary sector-specific guidelines to assist undertakings in the same sector in conducting their materiality assessment
  • Deletion of provisions on optional taxonomy reporting for certain undertakings

Corporate Sustainability Due Diligence Directive (CSDDD):

  • CSDDD scope is reduced to very large companies, with over 5,000 employees and EUR 1.5 billion in worldwide (or EU) turnover
  • A non-EU company falls under the CSDDD if it generated more than EUR 1.5 billion net turnover in the EU, measured in the FY preceding the last FY
  • Transition plans: provisions on the obligation for companies to adopt and put into effect a transition plan for climate change mitigation are deleted
  • Risk-based due diligence: companies must take a risk-based approach to identify and address potential adverse impacts, considering factors like geography, sector, product, and business partner risk. Companies do not have to request information from business partners when no likely and severe risks are identified

This vote follows the EP’s October plenary session, where MEPs rejected the Legal Affairs (JURI) Committee mandate to enter trilogues. As a result, MEPs from all political groups were able to table new amendments to the Omnibus proposal by 5 November, which were subsequently voted on during the mini-plenary session on 13 November.

Highlights

  • EP and Council adopt their position on 2040 climate target and signal EU commitment to climate neutrality
  • Council’s conclusions on future policy priorities
  • EU Member States call for delay and simplification of Deforestation Regulation
  • ESMA final report on EU Green Bond Regulation Technical Standards
  • IAASB publishes FAQs on ISSA 5000 relevance for CSRD assurance engagements
  • Trends in global corporate sustainability reporting

EU developments

Parliament and Council adopt their position on 2040 climate target and signal EU commitment to climate neutrality

EU environment ministers agreed on the Council’s general approach to a binding 2040 climate target of a 90% net reduction in greenhouse gas emissions under the European Climate Law. The Council highlighted that high-quality international credits could contribute to up to 5% in emission reductions. This milestone sets a long-term path towards climate neutrality by 2050, ensuring competitiveness and energy security.

Meanwhile, on 13 November, the EP in plenary session adopted the Environment, Climate and Food Safety (ENVI) report on the binding 2040 climate target and the referral back to the committee for interinstitutional negotiations.

Also, the Council approved the EU’s post-2030 Nationally Determined Contribution (NDC) for submission to the United Nations Framework Convention on Climate Change (UNFCCC). They establish an indicative 2035 reduction of 66.25–72.5%, bridging the 2030 target of 55% and the 2040 target.

Together, all these measures signal the EU’s commitment to the Paris Agreement and global climate action in view of COP30.

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Council’s conclusions on future policy priorities

EU leaders met to set the EU Council’s priorities for the months ahead. Among others, their conclusions on sustainability:

  • balance sustainability and competitiveness policy objectives, stressing that green and economic goals must go hand in hand
  • call on the EC to accelerate its work on all files with a simplification or competitiveness dimension, especially those with administrative burden and reporting requirements
  • urge the co-legislators to swiftly conclude work on the proposed simplification omnibus package on sustainability reporting and due diligence by the end of 2025
  • call for further simplification packages for several sectors, including the environment
  • call on the EC to further develop the enabling conditions to support the industry and citizens to achieve the 2040 intermediate climate target.

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EU leaders urge Council to act further on competitiveness

Several EU leaders submitted a letter urging the President of the European Council, António Costa, to restore Europe’s competitiveness by simplifying EU regulation, calling for:

  • reviewing existing rules to remove unnecessary or outdated ones
  • refraining from introducing new legislation
  • faster approvals for investment and innovation

On sustainability, leaders urged to:

  • speed up the pace of legislation adoption contributing to the simplification agenda, particularly the CSRD
  • simplify the CSDDD

They proposed to organise a special meeting of the European Council in February 2026 to review the work done and provide political guidance on competitiveness.

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EU Member States call for delay and simplification of Deforestation Regulation

EU Member States (MS) are increasingly opposing the planned entry into force of the EU Deforestation Regulation (EUDR) on 30 December 2025. On 27 October, agriculture ministers urged the European Commission (EC) to grant a one-year delay, citing implementation challenges, while the EC stressed the need for urgent agreement with the Council and the EP.

At a 29 October Coreper meeting, a large majority of MS rejected the regulation in its current form, calling for postponement and further simplification. Some supported a “stop-the-clock” to allow more time for assessment, while others favoured limited adjustments. Twenty-six European industry groups also urged a pause, warning that current simplification measures were insufficient and immediate compliance “unrealistic and unacceptable.”

At the Environment Council on 4 November, a broad coalition backed Austria’s call for a one-year delay and additional simplification measures, including targeted risk-based implementation, exemptions for low-risk areas, and reduced administrative burdens, citing IT system challenges and legal uncertainty.

Commissioner Jessika Roswall emphasised that the EC’s proposal already provides significant exemptions and stressed the need for rapid Council agreement before the EP negotiations.

On 13 November, the EP decided to use the urgency procedure to simplify the EU deforestation law. MEPs will vote on the content of the file during the 24-27 November plenary session in Strasbourg.

 

Berlin Declaration on European industry

The Berlin Declaration, endorsed by 17 EU Ministers of Industry, sets out a joint commitment to strengthen the European industry while accelerating decarbonisation. Key sustainability actions emphasised include:

  • creating lead markets for climate-friendly materials
  • promoting EU-validated carbon footprint labels
  • calling for measures to prioritise secondary raw materials and accelerate the single market for a circular economy
  • targeting public procurement to reward decarbonisation efforts

Overall, the declaration stresses the importance of simplified regulations, digitalisation, and flexible compliance. This would support low-carbon innovation, reduce emissions across value chains, and ensure Europe’s industrial sector remains competitive.

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EBA issues final guidelines on environmental scenario analysis

The European Banking Authority (EBA) guidelines aim to strengthen institutions’ ability to use forward-looking approaches to the assessment and management of environmental risks. The guidelines build on two pillars:

  • environmental risks integration into institution’s existing stress-testing frameworks
  • resilience analysis to evaluate medium to long-term implications of environmental risks and opportunities for banks’ business models, strategies and risks profiles

Guidelines will be applicable as from 1 January 2027.

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ESMA final report on EuGB Technical Standards

The European Securities and Markets Authority (ESMA) published its final report on the draft Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) under the European Green Bond Regulation (EuGB). ESMA is responsible for the registration and supervision of EU green bonds external reviewers.

The standards cover criteria for external reviewers regime on:

  • systems, resources and procedures
  • the compliance function’s authority, independence and resources
  • administrative, accounting procedures and internal control mechanisms
  • quality and reliability of information used in reviews
  • application content and format for recognition
  • notification templates for material changes.

ESMA submitted the revised draft RTS and ITS to the EC for adoption via delegated and implementing regulations.

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ESMA enforcement priorities

ESMA published its 2025 European Common Enforcement Priorities (ECEP) which also covers sustainability statements, specifically:

  • materiality considerations in reporting under the European Sustainability Reporting Standards (ESRS)
  • scope and structure of the sustainability statements

Also, ESMA clarified that the amended ESRS will only be applicable after they are published in the EU Official Journal. Therefore, issuers should not rely on these contents when preparing their upcoming sustainability statements.

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ESMA’s Q&A on SFDR

ESMA published a consolidated document outlining questions and answers on the Sustainable Finance Disclosure Regulation (SFDR) and its Delegated Regulation.

The document brings together the EC’s and the European Supervisory Authorities (ESAs) responses to key interpretative and practical issues, including scope, definitions of sustainable investment, and Taxonomy-aligned disclosures. It aims to clarify existing legal provisions without introducing new requirements.

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Stakeholders call on EU institutions to align competitiveness with green ambitions

More than 135 European businesses and investors sent a letter calling on EU policymakers to secure Europe’s competitiveness and technological leadership through the Clean Industrial Deal (CID). Signatories from 18 countries urged the EU to align climate ambition with industrial renewal, innovation, and strategic investments. They emphasised the need for stable regulation and targeted reforms. Among their priorities:

  • a 90% climate target by 2040
  • affordable clean energy
  • accelerated cleantech deployment and strategic investment
  • circular economy, and fair, cohesive green and digital transitions

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International developments

IAASB publishes FAQs on ISSA 5000 relevance for CSRD assurance engagements

The International Auditing and Assurance Standards Board (IAASB) released new FAQs to support the adoption of ISSA 5000, General Requirements for Sustainability Assurance Engagements. The FAQs explain the standard’s relevance to assurance engagements under the EU’s CSRD, as well as EU-specific considerations such as double materiality, scalability, and interoperability, helping stakeholders prepare for ISSA 5000’s effective date in December 2026.

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IOSCO publishes ESG indices as benchmark

The International Organisation of Securities Commissions’ (IOSCO) Sustainable Finance Taskforce report assessed environmental, social and governance (ESG) benchmarks, comparing them with traditional financial indices. ESG benchmarks incorporate ESG factors to guide investment and measure ESG risk or impact. While IOSCO’s Principles for Financial Benchmarks broadly apply, ESG data’s qualitative and evolving nature requires tailored oversight. According to the report’s findings:

  • administrators should ensure transparency, clear methodology, robust governance, and traceable ESG decisions
  • regular reviews are advised to address shifting standards and emerging sustainability risks
  • stronger safeguards against greenwashing are needed, emphasising accountability, rigorous data management, and proportional regulatory oversight to maintain the credibility, reliability and integrity of ESG benchmarks

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Trends in global corporate sustainability reporting

The Organisation for Economic Co-operation and Development (OECD)’s Global Corporate Sustainability Report 2025 shows global progress in integrating environmental and social goals into corporate strategies and governance. Key figures include:

  • by 2024, 91% of listed companies (by market capitalisation) disclosed sustainability information, and 81% received external assurance
  • board oversight of climate issues rose from 53% in 2022 to 70% in 2024, while 67% now link executive pay to sustainability targets.

The report calls for greater alignment across disclosure frameworks, stronger leadership from state-owned enterprises, and improved bankability of green energy projects. Overall, the findings highlight that sustainability is becoming a key driver of transparency, resilience, and long-term value creation.

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MEP questions & answers

Impact assessment on the amendment to the European Climate Law, broken down by individual Member States

  • Question by MEP Piotr Müller (ECR/Poland)
  • Reply by Commissioner Hoekstra

Other news

This curated content was brought to you by Vita Ramanauskaité, Accountancy Europe Senior Manager, Head of Sustainability, since 2015. You can send her tips by email, follow her on X and connect with her on LinkedIn.