EU: Sustainability initiatives in the Commission 2026 Work Programme

On 21 October 2025, the European Commission published its 2026 Work Programme. As usual, it includes a Communication and a set of Annexes. It is also accompanied by a press release, Q&A, and a factsheet.

The Commission's Work Programme represents an important milestone in the European Union’s annual policy-making cycle. Each autumn, the Commission publishes a document outlining the initiatives it intends to propose in the coming year. This year’s Work Programme, titled Europe’s Independence Moment, echoes themes articulated in Commission President von der Leyen’s State of the Union address (for more information, see our previous blog post). 

The 2026 Work Programme outlines actions to build a more sovereign and independent Europe in response to threats to security and democracy, conflicts and geopolitical tensions, risks to the economy and industry, and accelerating climate change.

This blog post focuses on the sustainability announcements in the 2026 Work Programme.

Focus on simplification

Alongside the 2026 Work Programme, the Commission published the 2025 Overview Report on Simplification, Implementation and Enforcement. The report highlights progress achieved so far, including six omnibus packages and other simplification proposals, aiming to deliver over €8.6 billion in annual cost savings for businesses and citizens.

The Commission aims to achieve a 25 per cent reduction in administrative burdens overall, and a 35 per cent reduction for small and medium-sized enterprises (SMEs), translating into €37.5 billion in savings for citizens, businesses, and public administrations by the end of its current mandate.

More than half of the actions in 2026 Work Programme consist of new simplification initiatives and omnibus packages. As outlined in the report, each Commissioner has been tasked with carrying out a comprehensive review and stress test of the EU legal framework within their remit. This exercise, coordinated by the Commissioner for Implementation and Simplification, aims to simplify, codify, and consolidate EU regulation to ensure it remains relevant, proportionate, and fit for purpose.

Over the next four years, the Commission would like to rely on the European Parliament and the Council to sustain - and even accelerate - the work on the omnibus packages and other simplification proposals. However, as seen in the context of the Omnibus I process (see our latest blog post), it is not always possible for the Commission to rely on the Parliament and the Council to expedite simplification proposals. Moreover, the results are sometimes unpredictable and may go far beyond the Commission’s original intent, especially when substantive changes are involved.

Key sustainability initiatives

Below is a list of key initiatives from 2026 Work Programme most relevant to ESG and sustainability. We will update this table as and when there are new developments.

This table was last updated on 28 October 2025.

Notable absences and ongoing proposals 

The 2026 Work Programme contains very few new environmental initiatives.

One of the most notable absences is the European Climate Adaptation Plan, which the Commission had previously announced as part of the Competitiveness Compass and expected for 2026 (for more on the Competitiveness Compass and sustainability, see our previous blog post).

The Environment Omnibus is also not mentioned, most likely because it is still planned for release before the end of 2025 (see our previous blog post).

The review of the Sustainable Finance Disclosure Regulation (SFDR) is not included, presumably as its publication is anticipated in November 2025.

In addition, the revision of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation is absent. Presumably, the Commission does not yet have a plan for it following the Regulatory Scrutiny Board’s (RSB) negative opinion on the impact assessment of this revision.

The proposal for a Green Claims Directive remains listed among ongoing files. In June 2025, an European Commission spokesperson indicated that the Commission intended to withdraw that legislative proposal. The Council then cancelled the third trilogue meeting with the European Parliament which had been scheduled for 23 June. On 23 June, the European Parliament’s co-rapporteurs confirmed that the Parliament remained ready to continue negotiations on this file. On 25 June, Commission Executive Vice-President Teresa Ribera clarified that the Commission had not officially withdrawn the Green Claims Directive, despite its previous announcement. In the meantime, the Council’s Danish presidency has been trying to resurrect discussions on this file but it is unclear whether there has been any progress. For more information on the Green Claims Directive, see our previous blog posts here and here. In addition, discussions are still ongoing in respect of: 

• substantive changes to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) as part of the Omnibus I proposal (see our previous blog post); and 

• the Commission’s proposal for a new 2040 climate target (see our previous blog post). We are hoping to find out what the next steps are on this file after the Council’s meeting of environment ministers on 4 November. 

Further reading

For more information on the Commission’s general direction of travel on sustainability matters, see our previous blog posts:

• EU: What does the 2025 State of the Union say about sustainability?
• European Commission delays Level 2 acts in sustainable finance legislation
• EU Omnibus Tracker: simplification of sustainability rules