Sustainability update

• EC launches consultation on CS3D implementation guidelines
• EC adopts Regulatory Technical Standards for ESG rating providers
• PSF delivers recommendations on Taxonomy Delegated Acts
• SEC proposes rescission of climate disclosure rules
• ISSB-GRI joint statement

EC launches consultation on CS3D implementation guidelines

This public consultation will inform the development of guidelines to support the effective implementation of the Corporate Sustainability Due Diligence Directive (CSDDD). It aims to identify practical challenges and stakeholder expectations as companies prepare to implement the EU’s new due diligence requirements covering human rights and environmental impacts across their operations and value chains.

The European Commission (EC) will issue guidelines that provide practical orientation to companies on how to fulfil their due diligence obligations, to Member State authorities on how to implement and enforce the Directive, and to stakeholders on how to pursue their rights. The guidelines will also be relevant for companies and other stakeholders in non-EU countries that are linked to the supply chains of companies with obligations under the Directive.

Stakeholders are invited to provide feedback until 24 July 2026. Final guidance is expected in the first quarter of 2027.

EC adopts Regulatory Technical Standards for ESG rating providers

The EC has adopted the Regulatory Technical Standards specifying information that the Environmental, Social, Governance (ESG) rating providers seeking ESMA authorisation or recognition should submit. Specifically:

• articles 1 and 2 define the precise information criteria for providers seeking ESMA authorisation or recognition
• article 3 outlines the formal application format
• articles 4 and 5 specify requirements regarding employee data and internal policies

The Regulation has been sent to the European Parliament (EP) and the Council for a scrutiny period of three months.

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EC triggers infringement procedures on Empowering Consumers for the Green Transition Directive

The EC has launched infringement proceedings against 20 Member States (MS) for failing to fully transpose the Empowering Consumers for the Green Transition Directive by the March 2026 deadline.

This directive aims to tackle greenwashing and early obsolescence by ensuring that shoppers receive clearer information on product durability, repairability, and legal guarantees. The affected MS have two months to respond to the formal notices before further enforcement action may be taken.

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ECON debates SFDR review report

The EP’s ECON committee recently debated the draft report on the Sustainable Finance Disclosure Regulation (SFDR) review.

Rapporteur MEP Gerben-Jan Meindert Gerbrandy (Renew/The Netherlands) welcomed the EC’s proposal as a strong foundation for simplifying the rules while calling for greater transparency and further simplification. Among MEPs’ reactions:

• both the EPP and the Greens broadly supported the rapporteur’s direction, with the Greens calling for sharper anti-greenwashing measures and clearer terminology
• right-leaning political groups were more critical of the report. The PfE requested excluding professional investors and managers from the retail investors’ criteria, and the ECR strongly opposed excluding sovereign securities.

A final vote in the ECON Committee is scheduled for 15 July 2026.

PSF delivers recommendations on Taxonomy Delegated Acts

The Platform on Sustainable Finance (PSF) has submitted 280 recommendations to the EC following a five-week review of the draft revised EU Taxonomy’s Climate and Environmental Delegated Acts (DAs).

The feedback primarily focuses on sectors, such as transport, manufacturing, construction and real estate, forestry and energy. The PSF prioritised specific areas aiming to enhance usability and consistency across activities, clarifying the approach and rationale for establishing criteria, policy coherence, and environmental ambition.

The PSF made two general recommendations to facilitate practical application:

• upgrading the Taxonomy Compass by linking each criterion to relevant sectoral legislation and databases, while also incorporating guidance to support implementation of the criteria, and
• conducting a comprehensive review of all taxonomy-related FAQs to ensure alignment.

Looking ahead, the PSF also highlighted five cross-cutting areas for medium-term reflection, including data alignment with the EU Emissions Trading System (ETS).

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ESMA issues GLESI compliance table

The European Securities and Markets Authority (ESMA) issued National Competent Authorities (NCA) compliance table with the Guidelines on Enforcement of Sustainability Information (GLESI) in European Economic Area (EEA) countries.

Out of 31 NCA, including two in Denmark, the current state of play is: 15 comply,6 do not comply, and 10 intend to comply soon.

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SEC proposes rescission of climate disclosure rules

The U.S. Securities and Exchange Commission (SEC) proposed the rescission of the climate-related disclosure rules. Following a September 2025 order from the Eighth Circuit Court to review the regulation, the SEC now proposes its abolition, arguing that the rules:

• are unnecessary and inconsistent with a registrant-specific, materiality-based approach to disclosure that best serves the interests of registrants and investors
• stray well beyond the policy concerns of the federal securities laws
• impose substantial costs on public companies and their shareholders that are not justified by the informational benefits they may provide to some investors
• are at odds with the SEC’s policy objectives of facilitating capital formation and promoting public company status.

The public comment period on this decision is open for 60 days.

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ISSB-GRI joint statement

The Global Reporting Initiative (GRI) and the IFRS Foundation have issued a statement on how they are working together to enable a seamless, global and comprehensive system. Specifically, they are working to:

• identify and align common disclosures, and
• explain how their complementary disclosures, e.g. transition plans, climate adaptation, can be used together to facilitate reporting for entities choosing or being mandated to meet the information needs of investors and other stakeholders.

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Impact of the Omnibus I simplification package on requesting sustainability information from companies and business partners

• Question by Catarina Vieira (The Greens/The Netherlands)
• Reply by Commissioner Albuquerque

Reporting obligations concerning hazardous substances under the CSRD

• Question MEPs from The Greens, S&D, Renew, and The Left
• Reply by Commissioner Albuquerque

Workshops in the application of the CSDDD

• Question by Christine Schneider (EPP)/Germany)
• Reply by Commissioner McGrath