ESG newsletter - July 2026

Spotlight on CSRD and CSDDD

We have a number of materials on the EU Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD / CS3D), including changes made by the Omnibus I package:

• EU Corporate Sustainability Reporting Directive: impact of CSRD on non-EU companies
• EU Corporate Sustainability Due Diligence Directive: impact of CSDDD on non-EU companies
• EU CSRD and Omnibus I: Transposition Tracker
• EU CSDDD Transposition Tracker
• ESG Quick Guide: EU Corporate Sustainability Reporting Directive (CSRD)
• ESG Quick Guide: EU Corporate Sustainability Due Diligence Directive (CSDDD / CS3D)

Global: SBTi publishes new, updated corporate net zero standard

In June, the Science Based Targets initiative (SBTi) published a new version of its Corporate Net-Zero Standard (V2.0). This is an updated version of its voluntary global framework for companies setting science-based emissions reduction targets aligned with 1.5°C pathways and net-zero by 2050. Over 11,000 companies have already set SBTi-validated targets under the previous version. V2.0 marks a significant evolution, moving from a pure target-setting exercise to an action-oriented framework embedded in business decision-making. Key features of V2.0 include differentiated requirements based on company size and geography, a “best-efforts approach” that acknowledges real world implementation barriers, a structured three-level hierarchy for delivering on targets, and a new voluntary Ongoing Emissions Responsibility (OER) programme. V2.0 takes effect from February 2027. The previous version (V1) remains open for new target submissions until the end of 2027. Companies with existing 2030 targets under V1 are expected to begin setting V2.0 targets for their next cycle (2030–2035) from 2028. For more information, see Foreword and Executive Summary, Getting Started with Version 2.0 and the Corporate Net Zero Standard version 2.

Global: ISO consults on draft international net zero standard

On 17 June 2026, the International Standards Organization (ISO) opened a 12-week public consultation on its draft net zero standard for non-financial institutions. This will transform ISO's existing Net Zero Guidelines into a verifiable standard — meaning claims would need to be independently validated, not self-declared. For more information, see our blog post. 

EU CSRD: Commission adopts revised ESRS and voluntary reporting standard

On 3 July 2026, the European Commission adopted two Delegated Acts comprising the revised European Sustainability Reporting Standards (ESRS) and the voluntary reporting standards under the Corporate Sustainability Reporting Directive (CSRD). The Council and the European Parliament will now scrutinise both Delegated Acts for two months (extendable by a further two months). If neither institution objects within the review period, the Acts will be published in the Official Journal and enter into force. For more information, see our blog post. 

UK: Government review of SECR suggests retaining regime with targeted amendments

The Department for Energy Security and Net Zero (DESNZ) published the outcome of its post-implementation review (PIR) of the Streamlined Energy and Carbon Reporting (SECR) regime on 26 May 2026. The headline recommendation is that the SECR should be retained, but that targeted amendments should be made to enhance its effectiveness, reduce duplication, and improve coherence with the UK's evolving sustainability reporting landscape. The SECR regime has been in force since 1 April 2019 and requires in-scope UK companies and LLPs to disclose certain information on their energy use and greenhouse gas emissions — focusing primarily on Scope 1 and Scope 2 — in their annual reports. The PIR’s recommendations are not final decisions. Any changes to the regime will need go through consultation and take into account proportionality and interoperability with related schemes. For more information, see our blog post. 

European Ombudswoman’s decision on Omnibus I process following NGO complaint

On 23 June 2026, the European Ombudsman published its Decision on the European Commission’s compliance with its ‘Better Regulation’ rules and other procedural requirements in preparing legislative proposals that it considered to be urgent. 

A formal complaint in respect of three legislative proposals, including Omnibus I, was filed by NGOs, including ECCJ, ClientEarth and Friends of the Earth Europe with the European Ombudswoman on 18 April 2025. The Ombudswoman announced on 27 November 2025 that she had found a number of procedural shortcomings in how the Commission prepared these legislative proposals.

In its reply, the Commission agreed to reflect on defining "urgency" during its upcoming revision of the Better Regulation rules, to record and publish derogation decisions, to conduct targeted consultations on urgent proposals, to publish supporting analytical documents within three months of adoption, and to include climate consistency assessments in both analytical documents and explanatory memoranda. 

However, the Ombudsman remained concerned that the Commission's commitments are expressed in general terms only and lack specificity, and that the concept of "political context" as a parameter for urgency is too vague, risking that recourse to urgent law-making could become routine rather than exceptional. 

The Ombudsman closed the three cases on the basis that the Commission broadly agreed to implement her recommendations, but made clear that the effectiveness of the concrete measures remains to be assessed and that she will monitor the matter once the Better Regulation rules have been revised and applied. For more information on the Omnibuses and the NGO complaint, see our EU Omnibus Tracker.

EU: political agreement reached on Defence Readiness Omnibus

The Commission published the Defence Readiness Omnibus on 17 June 2025. 

The Defence Readiness Omnibus package comprises three legislative proposals:

• a Regulation on the acceleration of permit-granting for defence readiness projects; 

• a Regulation amending the REACH, CLP, Biocidal Products and POPs Regulations, as well as the European Defence Fund (EDF) Regulation; and

• a Directive simplifying intra-EU transfers and security and defence procurement. 

Together, the measures aim to facilitate up to EUR 800 billion in defence investments over the next four years by removing administrative, regulatory and permitting barriers to the ramp-up of European defence industrial production.

On 10 June 2026, the Council and Parliament reached political agreement on these legislative proposals. See press releases from the Council and the Commission. 

From an environmental perspective, the provisional agreement retains the Commission's proposed amendments to EU chemicals legislation, which broaden Member States' discretion to exempt defence readiness activities from requirements under REACH, CLP, the Biocidal Products Regulation and the POPs Regulation. 

On permitting, the standard deadline for granting permits was fixed at 42 working days as proposed by the Commission, but the co-legislators introduced the possibility of a single extension of up to 60 additional working days where the project raises exceptional risks to health, safety of workers, or the environment, bringing the maximum total to 102 working days. 

The co-legislators retained the tacit approval mechanism (where if if no decision is taken within the time limit, permits are deemed granted) but added an explicit derogation allowing Member States to disapply tacit approval, by national law adopted within 12 months of entry into force, where the competent authority demonstrates on the basis of duly substantiated and verifiable evidence that the specific project raises a grave risk to human health or national security.

The provisional political agreement must now be formally endorsed by the Council and European Parliament before formal adoption in the coming months. For more information on the Defence Readiness Omnibus, see our publications here and here. 

Commission published Energy Omnibus proposal

The Commission published a proposal for a Regulation on simplification and better use of digital options for energy and tyre labelling (Energy Omnibus) on 24 June 2026.

The proposal aims to reduce administrative burdens for suppliers and retailers while maintaining clear and comparable information for consumers. 

Key measures include:

• introducing more flexible display options (e.g. digital labels, QR codes, and earlier provision of labels in sales processes);

• simplifying updates when energy ratings are rescaled;

• clarifying responsibilities for non-EU manufacturers’ representatives; and

• easing certain requirements for tyre labelling (e.g. removing display obligations for car dealers).

For more information on the status of various Omnibus legislative proposals, see our EU Omnibus Tracker. 

EU: political agreement reached on Chemicals Omnibus 

The Commission published the Chemicals Omnibus (Omnibus VI) on 8 July 2025 (see our previous blog post). 

The political agreement reached between the European Parliament and the Council on 17 June 2026 covers targeted amendments to the Classification, Labelling and Packaging (CLP) Regulation, the Cosmetics Products Regulation, and the Fertilising Products Regulation. See Commission press release and the Council press release. 

It follows an earlier deal on the "stop-the-clock" mechanism, which had already postponed the application of the revised CLP Regulation to 1 January 2028. The political agreement extends this date to 1 January 2030 to align the date of application of the CLP Regulation, the Cosmetic Products Regulation, and the Fertilising Products Regulation. 

Other changes made by the co-legislators include: 

• CLP: relaxed label formatting rules and extended relabelling deadlines when substances are found more hazardous than previously thought.

• Cosmetics: risk-proportionate phase-out timelines for carcinogenic, mutagenic or reprotoxic (CMR) substances, with mandatory pre-market notification for nanomaterials preserved.

• Fertilisers: Commission tasked with modernising registration requirements for components that don't fit existing categories (e.g. micro-organisms, polymers).

According to the Council press release, the co-legislators will work towards formally adopting this part of the Chemicals Omnibus as soon as possible, in the course of 2026.

EU: Council agrees its negotiating position on SFDR 2.0 proposal

On 24 June 2026, the Council of the EU agreed its negotiating mandate on the Commission's proposal to make significant changes to the Sustainable Finance Disclosure Regulation (SFDR 2.0). Overall, the Council has welcomed the proposed changes to the SFDR, recognising that the current framework needs clarity, consistency and alignment with other EU sustainable finance efforts and the expectations of markets.  In substance, therefore, the Council preserves the new product categorisation framework proposed by the Commission, and instead proposes targeted calibrations on four main points: PAI indicators; fossil fuel exposures; public sector issuances; phase-in period to reach 70% threshold; and AIF opt-out for professional investors. Trilogues can begin once the European Parliament adopts its own negotiating position. In Parliament, the ECON committee vote is scheduled for 15 July with a plenary vote to follow in Q3 (date tbc). Provided there no significant delays in the Parliament, trilogue negotiations remain likely to start in early Q4 2026. For more information, see our blog post. 

EU: EBA publishes final draft ITS amending Pillar 3 disclosure framework on ESG risks

On 22 June 2026, the European Banking Authority (EBA) published its long-awaited final draft ITS amending the Pillar 3 disclosure framework on ESG risks, and introducing disclosure requirements on equity and shadow banking exposures. With regard to ESG-related risks disclosures, and in line with the CRR3 mandate, the amending ITS extends the scope of institutions required to disclose ESG information, covering not only large, listed institutions but also large non-listed and other institutions, SNCIs, and large subsidiaries. At the same time, the EBA says that it is taking a proportionate and streamlined approach to ESG disclosures. The EBA will submit the final draft ITS to the European Commission for adoption. For more information, see our blog post. 

EU: EBA finalises its guidelines on product oversight and governance to address greenwashing risks in ESG retail banking products

The European Banking Authority (EBA) has published its final report on revised Guidelines on product oversight and governance (POG) arrangements for retail banking products. The revised Guidelines, published on 30 June 2026, make targeted amendments to make ESG and greenwashing considerations more explicit throughout the product lifecycle, particularly when the products are marketed to consumers. The Guidelines will be translated into the official EU languages and published on the EBA website. The deadline for competent authorities to report compliance will be two months after publication of the translations. The Guidelines apply from 11 January 2027. For more information, see our blog post.

EU: General Court annuls exclusion of business jet manufacturing aircraft intended for private or commercial business aviation from the EU Taxonomy

On 24 June 2026, the EU General Court annulled part of a Commission Delegated Regulation 2023/2485 that excluded the manufacture of aircraft intended for private or commercial business aviation from the EU Taxonomy's list of "transitional" activities contributing to climate change mitigation (Case T-77/24, Dassault Aviation v Commission). See Decision and press release.

The EU Taxonomy Regulation establishes a classification system for sustainable activities. In 2023, the Commission adopted a delegated regulation which, (among other things) set out technical screening criteria (TSC) for the classification of aircraft manufacturing but excluded business aircraft from the scope of activities regarded as contributing to climate change mitigation. Dassault Aviation, the French manufacturer of Falcon business jets, brought an action for annulment before the General Court, which upheld the action. 

The General Court identified three main flaws in the Commission's reasoning. First, the Commission based its assessment on CO2 emissions per passenger kilometre - a metric not provided for in the Taxonomy Regulation, which relates to the manufacture of aircraft rather than their operation. Second, the Commission could not treat other modes of transport as necessarily constituting low-carbon alternatives to business aircraft, given their specific characteristics in terms of CO2 emissions, flexibility, speed and connectivity. Third, and perhaps most significantly for the sector, the Commission failed to take into account the ability of business aircraft to operate on sustainable aviation fuels - and had itself acknowledged that further analysis was necessary.

The Commission stated it would assess whether to file an appeal. In this case, the General Court acted as the court of first instance; any appeal to the Court of Justice is limited to points of law. The ruling does not automatically make business jet manufacturing Taxonomy-eligible. It removes the express exclusion and requires the Commission to revisit its assessment. Manufacturers and investors in the aerospace sector should monitor whether the Commission appeals and, if not, how it proposes to reassess the classification.

ESMA, EBA and EIOPA consult on simplifying EU Taxonomy disclosure framework

The European Supervisory Authorities (ESAs) (i.e ESMA, EBA and EIOPA) have launched a consultation on technical advice to the European Commission on selected KPIs under the Taxonomy Disclosures Delegated Act.

ESMA proposes several simplifications to the Taxonomy disclosure framework for non-financial undertakings and asset managers. These include the operational expenditure KPI, addressing stakeholder concerns about complexity and reporting burden. ESMA also seeks feedback on a possible pragmatic solution for group-level reporting in mixed groups, based on the parent undertaking’s reporting model.

EIOPA suggests revising the current ‘underwriting KPI’ for (re)insurers by narrowing the denominator in the Taxonomy and Eligibility ratios to Taxonomy-eligible lines of business only and renaming the KPI to ‘Adaptation Underwriting KPI’. It also suggests simplifying reporting templates by removing disclosures on the breakdown of gas and nuclear activities and give more prominence to Taxonomy disclosures within insurance undertakings’ annual reports.

EBA proposed aligning the grandfathering provisions for financial instruments under Taxonomy disclosures with those set out in the EU Green Bond Regulation, and clarifying and improving group-level disclosures, including those by parent undertakings and other undertakings within the group.

The consultations will close on 12 August 2026. The ESAs will deliver their final technical advice to the Commission by the end of October 2026.

EU: ESMA issues statement on publication or distribution of ESG ratings by third parties pending authorisation

ESMA has issued a statement on the publication or distribution of ESG ratings by third parties in the period from 2 July 2026 until authorisation, recognition or registration of ESG rating providers under the ESG Rating Regulation. The statement clarifies whether third parties that are publishing or distributing ESG ratings of existing, but unauthorised, ESG rating providers will be able to continue doing so from 2 July 2026, when the ESG Ratings Regulation applies. For more information, see our blog post. 

UK: FCA consults on simplifying product-level TCFD disclosures

On 5 June 2026, the FCA published a consultation which proposes changes to simplify existing product level TCFD disclosures for the financial sector. The consultation comes off the back of concerns that existing rules result in disclosures that are too complex for retail investors to engage with. The new proposals aim to replace many of the existing TCFD product-level reporting requirements (primarily set out in the FCA Handbook ESG 2.3) with more targeted outcomes-based requirements. The consultation closes on 13 July 2026 and the FCA is aiming to finalise and implement the changes in the autumn. For more information, see our blog post. 

EU CSDDD: Commission consults on implementation guidelines

The European Commission launched a public consultation on 12 June 2026 on the development of guidelines to support the implementation of the Corporate Sustainability Due Diligence Directive (CSDDD / CS3D). The consultation closes on 24 July 2026. The adoption of these guidelines, in principle by July 2027, will mark a significant milestone in the operationalisation of the CSDDD, as they will shape expectations on how in-scope companies are expected to discharge their due diligence obligations in practice. For more information, see our blog post. 

EU Forced Labour Regulation: Commission publishes final guidelines 

On 30 June 2026, the European Commission published its guidelines on the application of the EU Forced Labour Regulation (FLR), together with the launch of a dedicated Forced Labour Single Portal. The guidelines provide clarification on the Regulation’s scope, and enforcement and implementation ahead of its application on 14 December 2027. The guidelines can be accessed through a new Forced Labour Single Portal which also contains others practical resources for in-scope businesses (e.g. a preparedness checklist and a list of national enforcement authorities). The Portal will be expanded over time, notably with a risk database identifying high-risk products and regions. For more information, see our blog post. 

UK government to introduce mandatory due diligence regime targeting deforestation in supply chains

The government has announced plans to introduce a mandatory due diligence regime targeting deforestation in supply chains (also known as the Forest Risk Commodities Scheme). Businesses operating in Great Britain (England, Scotland or Wales) with an annual turnover exceeding £1 million that use or place forest risk commodities — including cattle, cocoa, coffee, palm oil, rubber, soy, and wood, as well as derived products such as chocolate and furniture — on the market would be required to conduct due diligence to ensure compliance with relevant local laws. This includes collecting detailed supply chain information and geolocation data identifying the origin of products. Notably, Northern Ireland will be subject to the EU Deforestation Regulation (EUDR). While the GB regime is broadly designed to align with the EUDR, a key distinction is that it will initially focus only on illegal deforestation (i.e. compliance with local laws in the country of production), rather than adopting the EUDR's wider requirement that products be entirely deforestation-free — though the UK government has indicated it may move towards that standard in due course. The framework will be developed in stages, with a detailed consultation expected later in 2026 and legislation anticipated in 2027. For more information, see Government press release and policy statement. 

Global: PFAs podcasts 

We have produced two podcasts on PFAs, also known as “forever chemicals”: 

• Podcast: Overview of PFAs regimes in the UK, EU and US
• Podcast: How to deal with PFAs in M&A transactions

UK: Seventh Carbon Budget enacted

On 25 June 2026, the Carbon Budget Order 2026 was made and came into force. The Order sets the UK government's seventh carbon budget, setting the UK's greenhouse gas (GHG) emissions cap for 2038-2042. This is designed to achieve an 87% GHG emissions reduction from 1990 levels and include emissions from international aviation and international shipping. The Climate Change Act 2008 requires the UK government to set five-year carbon budgets to achieve its GHG emissions targets, including the UK's 2050 net zero target. The government is required to set out a delivery plan for the seventh carbon budget period soon after the Order has been made. For more information on the Order, see the Explanatory Memorandum.

UK: Government launches first climate security taskforce

On 26 June 2026, Climate Minister Katie White announced the launch of a first-of-its-kind expert taskforce to advise government on how to better anticipate and respond to the growing risks climate change poses to national security. Co-chaired by Climate Minister Katie White and Security Minister Dame Angela Eagle, the taskforce will examine how climate impacts overseas could create domestic pressures (including increased migration), and assess risks to food and water supplies, energy systems, financial markets and critical infrastructure. The announcement came during London Climate Action Week against a backdrop of record June temperatures. For more information, see UK government press release. 

Global trends in climate change litigation: 2026 snapshot

On 25 June 2026, the Grantham Research Institute on Climate Change and the Environment published its annual report on key trends in climate litigation from 2025 to May 2026. 

Key highlights from the report include the following:

• Climate litigation continues to grow at a record pace, with 249 new cases filed across 62 countries last year, bringing the global total since 1986 to 3,600 — more than three quarters of which have been filed since the Paris Agreement in 2015.
• Notable recent successes include the UK Supreme Court's landmark Finch ruling, which established that downstream (Scope 3) emissions must be considered in Environmental Impact Assessments, and the International Court of Justice's 2025 advisory opinion confirming states' legally enforceable duties to address climate change — a development that prompted the first major "polluter pays" case in the UK, filed by survivors of Super Typhoon Odette against Shell.
• However, for the first time, around 12% of new cases have been classified as "anti-climate litigation", reflecting a growing backlash against pro-climate legal wins through litigation, legislation, and regulatory rollback. In the UK, this includes investor challenges against the government following successful environmental cases, and proposals — backed by some political parties — to reverse the Finch ruling entirely. 

For more information, see Global trends in climate change litigation: 2026 snapshot.

EU: Directive on Empowering Consumers for the Green Transition 

The Empowering Consumers for the Green Transition Directive (also known as “EmpCo" or “ECGT” ) will start applying from 27 September 2026. From that date, companies must ensure that their commercial practices (including green claims and use of sustainability labels) comply with the requirements introduced by the new rules, including for products already on the market. EU Member States had to implement the Directive into national legislation by 27 March 2026 - although some still not have done so. For more information on this Directive, see our client briefing and Transposition Tracker. 

We held a webinar on on 9 June 2026 on EmpCo: what it does, how it fits alongside wider EU and UK action on greenwashing, and where businesses are most likely to feel the impact in practice, from marketing and labelling to customer communications and litigation risk. Click here to view the webinar recording and slides.   

We held a webinar on on 1 July 2026 on how EmpCo applies to financial services firms. Click here to view the recording and slides. 

On 30 June 2026, the Consumer Protection Cooperation Network (CPC) – which is the network of national consumer protection authorities – published a Common Understanding outlining how national authorities will enforce EmpCo in respect of goods that were already made and in circulation in the EU market by the date of application of the Directive (i.e. “old stock situations”). National authorities have agreed to take into account genuine transitional difficulties and practical constraints, such as stock volumes, product shelf-life, or technical feasibility. In such cases, national authorities will also prefer preventive measures before considering sanctions, such as providing clarifications to businesses concerned. Member States had until 27 March 2026 to transpose the Directive into national law. The Directive will start applying on 27 September 2026.

See also our blog post on how sports organisations can stay ahead of the game and not fall foul of the new EU rules under EmpCo. 

EU: Greenwashing complaints against major energy companies

A coalition of 13 European consumer rights watchdogs, led by BEUC, filed a complaint with the European Commission on 16 June 2026 accusing four energy companies of misleading consumers through: (i) using generic green claims and sustainability-related imagery despite relying on fossil fuel production and sales; (ii) making long-term net zero commitments while investing in fossil fuel extraction; and (iii) making misleading comparative claims about products. The BEUC urged the Consumer Protection Cooperation (CPC) Network - which is the network of national consumer protection authorities - to compel the companies to stop making the relevant claims and to issue fines if they continue. For more information, see the BEUC press release. 

UK: ASA bans ads from three fashion retailers over misleading 'recycled' claims

The Advertising Standards Authority (ASA) has banned advertisements from three fashion retailers (see the ASA decisions here, here and here) for making misleading environmental claims, specifically their use of the term “recycled” to describe fabric composition without adequate supporting evidence – following similar action taken in December 2025 against three other fashion retailers. 

UK: ASA retrospective on recent environmental rulings

The ASA has published a retrospective on recent environmental rulings covering the greener homes, fashion, green disposal, and travel sectors. The ASA has indicated it will continue monitoring green claims and will publish new guidance. For businesses with questions on non-broadcast environmental advertising claims, the CAP Copy Advice team can provide bespoke advice.

The ASA has also published a study analysing over seven million online ads using its AI-based Active Ad Monitoring system, finding that although only 1% of the ads analysed contained environmental claims, these claims were frequently expressed in broad or absolute terms that were difficult to substantiate.

Pay Transparency: Mind the (implementation) gap

7 June 2026 marked the transposition deadline for the EU Pay Transparency Directive (EUPTD). Yet only four Member States – Italy, Lithuania, Malta and Slovakia – have fully implemented it. The remaining countries are still progressing through implementation, leaving the compliance landscape fragmented and fast-evolving.

A few things are now clear (or rather, clear for now):

• The European Commission will not renegotiate or delay the EUPTD. The EUPTD will not be included in any omnibus simplification package or “stop-the-clock” measure.
• The absence of national implementing law does not remove exposure for employers. National courts are already expected to interpret domestic law consistently with the EUPTD.
• The four implemented regimes already differ materially from one another and should not be viewed as a blueprint for the rest of Europe.

In our blog post, our employment lawyers explore what this means in practice for employers operating across multiple jurisdictions.

EU Whistleblowing Directive in the spotlight for 2026

Despite full transposition across all 27 Member States, the gap between what the EU Whistleblowing Directive requires and how it operates in practice remains significant. Recurring challenges continue to surface across jurisdictions and enforcement is increasing. 2026 is also a milestone year for the Directive, which is currently subject to evaluation. Following the publication of the European Economic and Social Committee's report, the European Commission's own evaluation is still anticipated. Reporting channel arrangements remain a common area of concern, particularly for organisations operating across multiple entities. With further scrutiny on the horizon, now is a good moment to take stock – are you asking the right questions about your current whistleblowing setup? For more information, see our client briefing. 

China publishes guidelines for sustainable funds 

On 12 June 2026, the Asset Management Association of China (AMAC) released the following three guidelines targeting thematic funds, sustainable investing, and investor suitability: (i) Guidelines for the Management of Thematic Investment Style of Publicly Offered Securities Investment Funds; (ii)  Guidelines for the Application of Sustainable Investment Strategies for Publicly Offered Securities Investment Funds (Trial); and (iii) Detailed Rules for the Management of Investor Suitability for Publicly Offered Securities Investment Funds. Industry commentators see AMAC’s new guidelines for sustainability funds as likely to have a significant impact on China’s sustainable investment fund market by introducing quality standards comparable to the EU’s Sustainable Finance Disclosure Regulation (SFDR). The requirements include, for example, a requirement that funds invest at least 80% of their non-cash assets in line with their sustainability objectives and restrictions on the use of sustainability-related terms in fund names.

China publishes its National Human Rights Action Plan (2026-2030) 

On 11 June 2026, China published its National Human Rights Action Plan 2026–2030 (the Plan) at the opening of the 2026 Forum on Global Human Rights Governance. The Plan (which is the fifth such plan) represents a development of China's existing corporate human rights policy framework and reflects a continued recognition of environmental rights as an element of human rights protection. The Plan addresses environmental rights through four key pillars: (i) modernising environmental governance, including through the implementation of the Ecological and Environmental Code; (ii) advancing pollution prevention and control; (iii) enhancing the diversity, stability and sustainability of ecosystems; and (iv) addressing climate change. The Plan also emphasises greater public participation in environmental governance, expanded use of digital technologies in environmental monitoring and enforcement, and the further development of carbon management and emissions trading mechanisms, reflecting China's broader objectives of sustainable development and low-carbon transition.

Japan: SSBJ issues practical disclosure standard on use of Japanese GHG Reporting System

On 11 June 2026, the Sustainability Standards Board of Japan (SSBJ) issued a new Practical Sustainability Disclosure Standard No. 1, “Disclosure when Complying with ‘the Climate Standard’ Using GHG Emissions Measured and Reported in Accordance with the GHG Reporting System under the Japanese Act on Promotion of Global Warming Countermeasures” (the Practical Standards). The Practical Standards address the use of disclosures under Japan’s existing Greenhouse Gas (GHG) Reporting System when complying with the SSBJ’s Climate-related Disclosure Standard. This Practical Standard is intended to provide guidance on how entities can use data collected under Japan’s mandatory GHG reporting regime in meeting the SSBJ’s disclosure requirements, addressing a compliance burden raised by industry in having to comply with the different reporting regimes.

Japan issues a comment letter on the revised European Sustainability Reporting Standards (ESRS) for non-EU companies

The Government of Japan issued a comment letter dated 13 May 2026, on the Draft Delegated Regulation on revised European Sustainability Reporting Standards (ESRS) (the Comment Letter). The Comment Letter made the following proposals regarding N-ESRS (being the ESRS for non-EU groups): (i) to allow non-EU companies to use the sustainability report complying with IFRS Sustainability Disclosure Standards and provide any N-ESRS-specific disclosures, when necessary; and (ii) to allow non-EU companies, for topical standards other than climate-related standards, to choose between the global consolidated approach and an approach that allows the disclosure scope to be limited to impacts related to the EU (see FSA’s press release). 

Japan: METI revises its strategy for Japan’s battery industry

On 2 June 2026, Japan’s Ministry of Economy, Trade and Industry (METI) revised and renamed its August 2022 “Battery Industry Strategy” as the “Battery and Power Industry Strategy”. As referred to in METIs’ press release, the change reflects a growing need to provide comprehensive energy storage solutions to meet the advanced power control needs of certain sectors, including data centers. The updated strategy sets three key goals: (i) establishing a domestic manufacturing base of 150 GWh per year over the period from 2030 to the mid-2030s; (ii) tripling the global battery-related sales of Japanese companies over the period from 2025 to 2035; and (iii) capturing next-generation battery markets by achieving full-scale commercialisation of all-solid-state batteries around 2030 and establishing a manufacturing base in line with demand by the mid-2030s. 

Singapore: MAS updates good disclosure practices for retail ESG funds

On 10 June 2026, the Monetary Authority of Singapore (MAS) published an updated Information Paper on Good Disclosure Practices for Retail ESG Funds, amending its guidance originally issued in December 2024 (see our ESG Newsletter – February 2025). The update draws on MAS’ observations from thematic inspections of selected fund managers’ ESG funds conducted in 2025. Key additions to the guidance include: (i) a clarification that good practice requires clear, accurate, and complete descriptions of the ESG criteria or metrics used in a fund’s investment selection process; (ii) additional recommended disclosures where investments may be made without meeting a minimum ESG rating or score, including any alternative criteria or due diligence processes applied in such cases; and (iii) further disclosures recommended for ESG funds that track or reference ESG indices.

Singapore: Energy Transition Acceleration Finance Partnership under Singapore’s FAST-P initiative achieves first close

The Monetary Authority of Singapore (MAS), Clifford Capital, and the Private Infrastructure Development Group (PIDG) announced that the Energy Transition Acceleration Finance partnership (ETAF) - a blended finance fund under Singapore’s Financing Asia’s Transition Partnership (FAST-P) initiative - has achieved its first close with US$250 million in committed capital for its displacement strategy. ETAF seeks to mobilise capital into earlier-stage or higher-risk energy transition infrastructure investments where financing is not otherwise available at a sufficient scale, tenor, or risk appetite. ETAF is one of three funds under FAST-P alongside the Green Investment Partnership and the Industrial Transformation Programme, underpinned by the Singapore Government’s pledge of up to US$500 million in concessional capital under FAST-P with an overall target of catalysing up to US$5 billion for Asia’s green transition.

Singapore launches standard on sustainability excellence to strengthen business competitiveness 

Enterprise Singapore, through the Singapore Standards Council and in partnership with A*STAR Singapore Institute of Manufacturing Technology and the Singapore Manufacturing Federation, launched the Technical Reference (TR) 149:2026 Specification for Organisations to Progress towards Environmental Sustainability Excellence. The standard provides businesses with a structured framework to assess and improve their sustainability maturity across four progressive levels – Essential, Bronze, Silver, and Gold – spanning five dimensions including People Readiness, Structure, Operations, Supply Network and Product Life Cycle. 

Singapore’s C3T launches Green 100 Movement to support SMEs

The Council for a Competitive Climate Transition (C3T), co-chaired by the National Climate Change Secretariat and the Singapore Business Federation, launched the Green 100 movement to help SMEs to capture green growth opportunities. Green 100 brings together large enterprises to encourage and mobilise SMEs in their supply chains and business networks to take their first step in sustainability reporting and capability building. C3T plans to rollout future phases to expand the benefits for participating businesses.

Singapore Exchange and Gprnt announce partnership to upgrade the ESGenome Portal 

Singapore Exchange (SGX) and Gprnt, a digital sustainability platform launched by the Monetary Authority of Singapore, have announced a partnership to support SGX-listed companies in making climate-related disclosures (CRD) by upgrading SGX’s ESGenome Portal. With the partnership, the ESGenome Portal has been migrated onto the Gprnt platform and now leverages Gprnt’s sustainability reporting infrastructure to introduce a number of practical improvements for its users. The enhanced portal features (i) automated Scope 1 and 2 emissions calculations using trusted government data, (ii) CRD modules developed in consultation with relevant government agencies, incorporating guided workflows and plain-language prompts to support companies approaching climate reporting for the first time, and (iii) AI-assisted tools to be introduced on a phased basis, covering disclosure preparation, climate risk and opportunity assessments, and the development of climate targets and transition plans. The initiative is complemented by the involvement of the Council for a Competitive Climate Transition (C3T), co-chaired by the National Climate Change Secretariat and the Singapore Business Federation. C3T will engage Gprnt and SGX to provide listed companies with resources on climate risks, transition pathways and sectoral benchmarks, and to continually identify information gaps and additional resources needed to support transition planning. C3T is also encouraging listed companies to participate in the “Green 100” national movement by mobilising their suppliers, customers, and business partners to embark on basic sustainability reporting and capability building.

Hong Kong SAR: Government launches public consultation on first five-year plan with sustainability aspects

The HKSAR Government published, in June 2026, a public consultation on the First Five-Year Plan for Economic and Social Development of the HKSAR (2026–2030) (the Plan) (see press release). The Plan includes green finance as a pillar of Hong Kong’s “Finance+” strategy, alongside fintech and trade finance, as part of the broader agenda to consolidate and enhance Hong Kong's position as an international financial centre. The Plan sets out policy direction around promoting green living as well as green and low-carbon transition (including progressively ceasing the use of coal for daily electricity generation and supporting wider adoption of EVs); strengthening ecological conservation and environmental protection; and developing new energy, green technology, and innovative applications (including support for sustainable aviation fuel (SAF) and hydrogen technologies). The public consultation closes on 14 August 2026.

Hong Kong SAR: SFC publishes annual report with ESG / sustainable finance elements 

On 24 June 2026, Hong Kong’s Securities and Futures Commission (SFC) published its Annual Report 2025-26, providing an overview of its work in the financial year ending 31 March 2026 and outlining its strategic priorities. One of SFC’s strategic priorities is leading financial market transformation through technology and ESG, with the aim of embracing both technology and sustainable finance in order to future-proof Hong Kong’s financial markets. In respect of ESG, the annual report sets out that its key priorities are to advancing Hong Kong’s role as sustainable finance hub; adopting global sustainability disclosure standards; and contributing to voluntary carbon market development.

Federal Agency Actions

• On 26 June 2026, the National Oceanic and Atmospheric Administration (NOAA) published a Federal Register notice (91 FR 38674) announcing public meetings to solicit stakeholder input for a formal Section 312 Coastal Zone Management Act (CZMA) performance evaluation of California’s Coastal Management Program—a review initiated at the direction of Secretary of Commerce Howard Lutnick. The evaluation encompasses the California Coastal Commission and related bodies overseeing California’s 840-mile coastline, with NOAA specifically seeking new input regarding spaceport infrastructure, offshore oil production, pipeline maintenance, desalination projects, and undersea cables—areas where the Trump administration has repeatedly clashed with the Commission. Public meetings are scheduled for 10 August 2026 in Santa Monica and virtually on 11 and 12 August 2026, with comments closing 22 August 2026. A negative Section 312 finding could suspend California’s federal CZMA funding and is widely seen as a predicate for weakening the Commission’s federal consistency authority, which is the primary tool for objecting to offshore oil and gas leasing in federal waters.
• On 24 June 2026, the U.S. Environmental Protection Agency (EPA) published a proposed rule overhauling its procedures for implementing the National Environmental Policy Act (NEPA) under 40 CFR Part 6. The proposed rule draws on Executive Order 14154, the Fiscal Responsibility Act of 2023, the One Big Beautiful Bill Act of 2025, and the Supreme Court’s May 2025 decision in Seven County Infrastructure Coalition v. Eagle County. Key proposals include: (1) page limits of 150 pages for environmental impact statements (EISs)—300 pages for particularly complex actions—and 75 pages for environmental assessments (EAs); (2) mandatory completion deadlines of two years for EISs and one year for EAs; (3) a narrowed scope of required analysis, limited to the proposed action and its reasonably foreseeable environmental effects; and (4) a streamlined process allowing the EPA to adopt categorical exclusions from other agencies without formal rulemaking. EPA’s proposal is consistent with updates proposed and finalized by other federal agencies. Public comments are due on or before 27 July 2026.
• On 23 June 2026, the U.S. Department of Energy’s (DOE) Office of Energy Dominance Financing issued a conditional commitment of $17.5 billion in loan facilities to accelerate deployment of 10 large-scale commercial nuclear reactors. The financing is structured as up to five loans, each supporting two reactors to be developed by an eligible utility or energy company partnering with a nuclear technology company. Prior to accessing DOE funds, both the nuclear technology company and each partner must commit $500 million in upfront equity per project ($1 billion total). Long-lead items include reactor vessels, steam generators, turbines, and transformers, and the financing is designed to shorten deployment timelines by up to three years. Each AP1000 reactor generates approximately 1.1 gigawatts of power, with the 10 reactors combined expected to supply enough electricity for approximately 10 million American households. The announcement is a step toward implementing President Trump’s May 2025 executive order, “Reinvigorating the Nuclear Industrial Base,” which set targets of having 10 new large reactors under construction by 2030.
• On 18 June 2026, the Federal Energy Regulatory Commission (FERC) issued six tailored show cause orders under Section 206 of the Federal Power Act to each of the nation’s regional transmission organizations directing each to either demonstrate that its existing large-load interconnection tariff is just and reasonable or propose tariff revisions within 60 days, and to submit an informational report on resource adequacy within 30 days detailing how it will ensure adequate generation is available to serve both existing and new large loads. The orders identified five categories of reform: (1) developing efficient transmission service application and study processes including the use of alternative grid technologies; (2) preventing cost shifting and requiring transparency into transmission costs; (3) accommodating co-location arrangements and behind-the-meter generation; (4) providing new transmission services for flexible large loads; and (5) developing a process to study generating facilities serving electrically proximate or co-located large loads. FERC’s action responds to a directive issued in October 2025 by Department of Energy Secretary Chris Wright, which requested that FERC standardize interconnection procedures to ensure large loads can connect to the transmission system in a timely, orderly, and non-discriminatory manner.
• On 16 June 2026, the Department of War’s Office of Strategic Capital (OSC) announced a conditional $500 million long-term debt financing commitment to a mining and metals production company to scale domestic rare earth separation and metallization—the technically complex midstream process bridging raw extraction and permanent magnet production. Combined with additional private capital, the total initiative is intended to reach approximately $1 billion, supporting expansion of the company’s existing metallization facilities in the northeastern United States, as well as construction of a new domestic rare earth separation and metallization facility targeting initial operations in 2028. The conditional commitment remains subject to customary financial, legal, and technical due diligence before financial close, with the OSC Director David A. Lorch stating that the investment represents “an important step in strengthening the full mine-to-magnet supply chain in the United States.”
• On 4 June 2026, the DOE announced up to $500 million in Defense Production Act (DPA) Title III funding to support 13 coal-fired power plants and a new coal export facility, invoking a presidential determination issued by President Trump on 30 April 2026, authorizing DPA deployment for coal supply chains and baseload power generation. Of the total, $425 million will be directed to 12 modernization and capacity expansion projects across 10 states—including Tennessee, Kentucky, West Virginia, North Carolina, and Oklahoma—representing over 14 gigawatts of coal-fired capacity. The remaining $75 million will support construction of the West Gateway Terminal in Oakland, California, a rail-served marine export terminal capable of handling more than 10 million tons of bulk commodities annually, with first cargo shipment targeted by the end of 2028.
• Also on 4 June 2026, the U.S. Government Accountability Office (GAO) issued a decision examining whether the DOE properly managed its fiscal year 2025 funding in compliance with federal appropriations law. The decision noted a discrepancy between the spending figures DOE reported as officially authorized for FY 2025 and the amounts that Congress approved through a continuing resolution that carried forward FY 2024 spending levels. GAO concluded that program-level spending limits imposed by Congress were legally binding on DOE and should have been reflected accurately in the agency’s budget materials. GAO reviewed separate obligation data and found indications that DOE may have committed funding in excess of those congressionally set ceilings across five of the six accounts in question. GAO did not issue a definitive finding of a violation but found that if FY 2025 appropriations were spent beyond the authorized limits, DOE is obligated to self-report an Antideficiency Act violation.
• Also on 4 June 2026, the EPA issued a proposed rule that would allow the State of Louisiana to administer its own coal combustion residuals program, enabling state authorities—rather than the federal government—to issue permits for the closure and management of coal ash in surface impoundments and landfills. The proposal is consistent with a broader EPA initiative to delegate coal combustion residuals program authority to states, following similar approvals granted to five other states.
• On 2 June 2026, the U.S. Trade Representative (USTR) released findings under Section 301 of the Trade Act identifying 60 economies as failing to adequately prohibit or enforce bans on imports produced with forced labor—a practice USTR determined unreasonably burdens U.S. trade. Of those 60 investigated economies, 54 were found to have no meaningful prohibition in place, while six—Canada, Ecuador, the EU, Indonesia, Mexico, and Pakistan—had prohibition laws on the books but were found to be enforcing them ineffectively. In response, USTR has proposed additional import tariffs: 10% on goods from economies that have a forced labor prohibition or existing trade commitments with the United States, and 12.5% on goods from the remaining investigated economies, with certain exemptions, including goods qualifying under the U.S.-Mexico-Canada Agreement. The public may submit written comments by 6 July 2026, and a public hearing is scheduled for 7 July 2026 at the U.S. International Trade Commission.

Presidential Actions 

• On 11 June 2026, President Donald Trump signed a presidential proclamation allowing commercial fishing in the areas surrounding three Marine National Monuments in Hawaii, Guam, and American Samoa, ending decades-long bans on commercial fishing in these areas. This proclamation is part of the Trump administration’s push to open fishing opportunities, following industry efforts seeking higher catch limits and access to additional fishing areas. The administration previously ended fishing restrictions at two Marine National Monuments in New England in February.
• On 29 May 2026, President Trump signed Executive Order 14408, rescinding Executive Orders 11644 (1972) and 11989 (1977)—the approximately 50-year-old framework governing off-road vehicle use on public lands. The administration determined that the “minimization criteria” imposed by those orders—including requirements to minimize wildlife harassment and avoid adverse effects on natural, aesthetic, or scenic values—were too vague to operationalize and created barriers to energy and timber production, infrastructure maintenance, and recreation. The Order reasons that existing statutory authorities, including NEPA, the Endangered Species Act, and the Federal Land Policy and Management Act, provide a sufficient framework for managing off-road vehicle access without the rescinded criteria. Relevant federal agencies are directed to initiate rulemakings to rescind or revise all implementing regulations previously adopted under the now-rescinded orders.

Congressional Actions 

• On 10 June 2026, the U.S. House Committee on Natural Resources introduced a bill that would allocate approximately $2 billion to national parks and public lands over the next five years. The funding would be distributed across the National Park Service (NPS), the U.S. Fish and Wildlife Service, the Bureau of Land Management, the Forest Service, and the Bureau of Indian Education, with the majority going to the NPS. The agencies would be directed to prioritize repairing safety hazards, deteriorating infrastructure, and assets at risk of imminent closure. The bill incorporates several mechanisms aimed at reducing bureaucratic delays, including streamlined environmental review procedures, expedited contracting timelines, and acquisition flexibilities typically reserved for emergencies, while also encouraging public-private partnerships and philanthropic matching contributions for specific projects.

State Actions 

• On 25 June 2026, representatives from Washington, California, and Québec signed an agreement to link their carbon markets in an effort to decrease costs for carbon-emitting businesses, building on the existing California–Québec linkage that has been in place since 2014. The agreement establishes a framework for ongoing regulatory coordination, including mutual recognition and cross-border trading of carbon compliance instruments, joint auction procedures, and a shared electronic registry. The parties also committed to aligning their greenhouse gas emissions reporting standards, offset protocols, and market oversight mechanisms. If California and Québec adopt certain additional regulations, allowances from California and Québec could be traded in Washington’s Cap-and-Invest Program, allowing Washington businesses to use those credits to cover their emissions and vice versa.
• On 24 June 2026, the California Air Resources Board (CARB) announced that it intends to delay the first mandatory reporting deadline under California’s corporate greenhouse gas disclosure law, Senate Bill 253 (SB 253), from 10 August 2026 to 10 November 2026. CARB stated that the extension is intended to give covered companies additional time, as it plans to withdraw its implementing regulations from the California Office of Administrative Law to make limited changes—a step that may delay the regulations’ final approval.
• On 23 June 2026, the California Attorney General and California Energy Commission (CEC) Chair sent a Notice of Intent to Sue challenging the Department of the Interior’s (DOI) offshore wind lease buyouts under the Outer Continental Shelf Lands Act, alleging the Trump administration failed to afford California a meaningful role in leasing decisions; the CEC separately issued investigative subpoenas to the relevant developers demanding copies of their settlement agreements. The Notice targets a series of buyouts totaling nearly $2.6 billion, including a 17 June 2026 deal with a large renewable energy company—under which four leases were terminated in exchange for $765 million redirected toward natural gas and geothermal projects—and a 23 March 2026 settlement agreement with a globally integrated energy company, under which the company renounced two leases and pledged to invest approximately $928 million in U.S. liquefied natural gas and Gulf of America oil and gas production in exchange for dollar-for-dollar reimbursement.
• On 22 June 2026, 17 state attorneys general filed suit against the State of California, alleging that a new state law requiring producers of single-use plastic to reduce their use in packaging and food items by 25% and make those items recyclable or compostable by 2032 violates the Commerce Clause of the U.S. Constitution by effectively dictating packaging and manufacturing standards for businesses across the entire country. The complaint alleges further violations of both the U.S. Constitution and the California state constitution, including that the law restricts producers’ free speech rights by preventing them from communicating with consumers about the reasons for increased prices and that it impermissibly delegates regulatory authority to a private organization. The plaintiffs also contend that the law’s aggressive mandates are technically unachievable and would place the economic burdens of compliance on consumers.
• Also on 22 June 2026, the California Attorney General, the Governor, and the CARB filed suit in U.S. District Court for the District of Columbia, challenging the EPA’s decision to reclassify four longstanding California emissions exemptions as “rules” that Congress can overturn. The exemptions in question—known as Clean Air Act preemption waivers—allow California to set its own, stricter vehicle and engine emissions standards. The four waivers at issue relate to: California’s 2008 greenhouse gas emission standards for cars; its 2012 Advanced Clean Cars program; the Biden administration’s 2022 reinstatement of part of that program; and 2022 amendments to standards for small off-road engines.
• On 12 June 2026, the Alaska House of Representatives approved HB 381, advancing the Governor’s proposed tax framework for the Alaska liquefied natural gas project—a $54.5 billion development that would include a North Slope gas treatment facility, an 807-mile pipeline, and a Cook Inlet export terminal. The legislation would replace the standard oil and gas property tax regime with a throughput-based alternative that exempts the project from state and municipal property taxes until production reaches a specified threshold, reverting to the standard system if the developer fails to meet construction milestones by 2032. On 19 June 2026, the Senate passed the bill with substantial amendments, including the addition of an income tax on S-corporation entities that produce or transport oil or gas in Alaska and changes to the alternative volumetric tax rate. The House rejected the changes made in the Senate, so a conference committee with members from both chambers was appointed to reach a compromise.
• On 10 June 2026, the Texas Governor directed the Public Utility Commission of Texas (PUC) and the Electric Reliability Council of Texas (ERCOT) to take immediate steps to protect residential ratepayers from the infrastructure costs associated with the state’s rapidly expanding data center sector. In a letter to the PUC Chair and ERCOT CEO, the Governor issued three immediate directives: the PUC must require data centers to fully fund the costs of electric infrastructure needed to serve their operations, ensuring those costs are not passed on to residential customers; the PUC must initiate action to reduce residential ratepayers’ transmission costs by 31 July 2026; and both institutions must submit a joint memorandum to the Office of the Governor by 17 July 2026, identifying additional steps available under their existing authority to safeguard residential and small-business ratepayers. The Governor also pledged to work with lawmakers to codify those protections into statutes and to enact additional protective measures.
• On 5 June 2026, the New York state legislature passed the Responsible Data Center Development Act (S.10642), which would be the first statewide data center moratorium in the nation if signed by the Governor. The bill places a one-year moratorium on all new data center-related Department of Environmental Conservation (DEC) permits and requires the DEC to conduct a comprehensive environmental impact report on data center operations statewide. The Public Service Commission would be directed to establish new electric and water rate classes for data centers over 20 megawatts, requiring those facilities to cover all additional infrastructure and administrative costs associated with connecting to the grid and water systems. The bill also imposes labor standards for data center construction—including prevailing wage, collective bargaining, apprenticeship agreements, and “Buy American” requirements for iron and steel.
• On 2 June 2026, a seven-state coalition led by the New York Attorney General—joined by the attorneys general of Connecticut, Maine, Massachusetts, New Jersey, Rhode Island, and Vermont—filed suit in the U.S. District Court for the District of Columbia challenging DOI’s March 2026 settlement agreement with a globally integrated energy company, under which DOI agreed to cancel the company’s two offshore wind leases in exchange for a nearly $1 billion reimbursement from the federal Judgment Fund and a requirement that the company invest an equivalent amount in fossil fuel projects. The coalition seeks to vacate the settlement, restore the leases, and enjoin further implementation of the deal.
• On 21 April 2026, the Florida Attorney General issued Civil Investigative Demands (CIDs) to five major consumer goods and retail companies and three environmental organizations as part of an investigation into potential violations of the Florida Antitrust Act, alleging that the companies engaged in collusive partnerships with the named environmental groups that restricted trade, increased prices for consumers, and diminished free market competition in connection with coordinated plastics packaging initiatives, including the designation and elimination of so-called “problematic materials.” The CIDs required each recipient to produce documents by 27 May 2026; no public enforcement action has been announced following the expiration of that deadline. The action follows a 10 February 2026 letter from a coalition of 10 attorneys general to nearly 80 corporations warning that participation in those organizations could expose them to antitrust liability.

ESG Litigation 

• On 29 June 2026, the U.S. Supreme Court granted a petition for certiorari regarding an eminent domain dispute concerning how landowners should be compensated when natural gas pipeline developers acquire their property under the Natural Gas Act (NGA). In the initial case, North Dakota landowners attempted to recover attorneys’ fees from a pipeline operator following a settled eminent domain dispute, and the Eighth Circuit held that the NGA entitles landowners only to the minimum compensation required by the Fifth Amendment to the U.S. Constitution. Meanwhile, four other circuits have looked to state law, which frequently provides for higher awards, to determine compensation in NGA condemnation proceedings. The landowners’ petition for review noted this circuit split and requested that the Court resolve it.
• On 26 June 2026, the U.S. Court of Appeals for the District of Columbia Circuit upheld a 2024 federal rule that tightened the national air-quality limit on soot (fine particulate matter, or “PM2.5”), lowering the main annual health-based standard from 12 to 9 micrograms per cubic meter of air. The court rejected challenges brought by industry groups and several states, and also denied the EPA’s own request to withdraw the rule after the agency reversed its position and joined the challengers. It held that the Clean Air Act allowed the EPA to revise the standard ahead of its regular five-year review cycle without first conducting a full “thorough review” of the underlying science, and that established precedent bars the agency from weighing economic costs or practical attainability when setting these health-based standards.
• On 25 June 2026, the U.S. Supreme Court ruled in favor of an agrochemical company sued over its glyphosate-based weed killer, holding that federal pesticide law preempts the state-law claim against it. The claim was a “failure-to-warn” claim, meaning an allegation that the company should have warned users of a risk associated with the product. The relevant federal statute is the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs how pesticides are regulated and labelled in the United States. The claimant alleged that roughly two decades of using the product had caused his non-Hodgkin’s lymphoma (a type of cancer) and argued that the company should have included a cancer warning on the product’s label. A jury awarded him more than $1 million, and a Missouri state appeals court upheld that award. The Supreme Court reasoned that the EPA, the federal regulator, has repeatedly concluded that glyphosate is not likely to cause cancer and has not required a cancer warning. Federal law requires the manufacturer to use the EPA-approved label unless and until the EPA approves or requires a change. Because FIFRA is designed to keep pesticide labelling uniform across all states, it bars any state from imposing labelling requirements that go beyond, or differ from, the federal ones. The decision settles a disagreement among lower U.S. courts that had reached conflicting conclusions on the issue. Two of the nine Justices dissented, taking the view that the claim simply mirrors FIFRA’s own rule against false or inadequate labelling and so should have been allowed to proceed, and that the majority’s approach leaves the claimant without any way to recover.
• Also on 25 June 2026, the Washington state supreme court unanimously affirmed the state superior court’s dismissal of a lawsuit challenging the Washington Department of Ecology’s regulations implementing the agricultural fuel exemption under Washington’s Climate Commitment Act (CCA). The court held that the Department’s rules (which place the point of regulation on fuel suppliers rather than agricultural end users and establish a voluntary rather than mandatory framework for suppliers to report and document exempt fuel sales) are reasonably consistent with the CCA and did not exceed the Department’s statutory authority. The court further held that the Department’s denial of the agricultural industry association’s petition to reopen rulemaking was not arbitrary and capricious, finding that the Department had provided a reasoned basis for its denial and that suppliers had successfully implemented its guidance. The CCA, enacted in 2021, established a cap-and-invest program capping greenhouse gas emissions from large fuel suppliers while exempting fuel used exclusively for agricultural purposes when the buyer provides the seller with an exemption certificate.
• On 24 June 2026, the U.S. District Court for the District of Maryland dismissed as moot a challenge brought by environmental organizations against the National Marine Fisheries Service (NMFS), holding that the court lacked jurisdiction to proceed following the Endangered Species Committee’s unanimous 31 March 2026 vote to exempt all oil and gas exploration, development, and production activities in the Gulf of America from Section 7 of the Endangered Species Act (ESA) on national security grounds. The court found the case moot because the exemption rendered the challenged biological opinion and incidental take statement legally inoperative, eliminating any ESA obligation the court could remedy and depriving the court of a live controversy over the adequacy of NMFS’s species protections for Gulf oil and gas activities.
• Also on 24 June 2026, a U.S.-based chemical company agreed to a $450 million settlement with the U.S. Department of Justice (DOJ)—which the DOJ described as the first comprehensive federal enforcement settlement against a manufacturer of per- and polyfluoroalkyl substances (PFAS). Without admitting liability, the company agreed to: (1) pay a $22.5 million civil penalty in three annual installments split evenly between the United States and West Virginia; (2) fund up to $90 million over 15 years in U.S. EPA-supervised PFAS mitigation and emissions reduction projects; and (3) meet requirements for PFAS discharge controls, drinking water safety, and hazardous waste compliance at each facility involved.
• On 24 and 26 June 2026, federal courts in Kansas and Indiana granted preliminary injunctions blocking the enforcement of laws in those states that imposed mandatory disclosure obligations on proxy advisory firms when recommending votes against company management, requiring them to either produce a written financial analysis or publicly flag that no such analysis had been conducted. Both courts found that the laws amount to viewpoint discrimination prohibited by the First Amendment. The Indiana court found that the state’s law tracked a model statute explicitly aimed at proxy advisers promoting ESG and DEI agendas, while the Kansas court rejected the argument that the laws were neutral between pro- and anti-ESG positions. These decisions followed a similar preliminary injunction issued in Texas in 2025.
• On 23 June 2026, the U.S. Supreme Court issued a decision holding that federal courts cannot create new causes of action for violations of international law under the Alien Tort Statute (ATS) of 1789, and that the Torture Victim Protection Act of 1991 does not provide for aiding-and-abetting liability. The majority opinion ended a lawsuit brought by members of the Falun Gong spiritual movement who alleged that a technology company assisted China’s crackdown on the group by helping design and develop its “Golden Shield” internet surveillance system. The case was originally filed in 2011, initially dismissed in 2014, and revived by a divided Ninth Circuit panel in 2023 before the Supreme Court agreed to hear the company’s appeal. The ruling is the latest in a series of decisions narrowing the ATS’ scope, following the Court’s 2021 ruling in Nestlé USA, Inc. v. Doe, which required plaintiffs to allege domestic conduct beyond general corporate activity.
• Also on 23 June 2026, a divided panel of the U.S. Court of Appeals for the Tenth Circuit reversed and remanded two consolidated cases challenging former President Biden’s 2021 expansions of the Bears Ears and Grand Staircase-Escalante National Monuments in Utah under the Antiquities Act, brought by Garfield County, Utah and other plaintiffs. The majority held that the district court had “based its determinations on a flawed view of sovereign immunity’s ultra vires exception” in dismissing the plaintiffs’ claims, and that federal courts have authority to review whether presidential monument designations remain within the Act’s statutory limits, including its requirement that monument boundaries be “confined to the smallest area compatible” with the objects to be protected. The majority declined to rule on the merits of the monument expansions, remanding the cases for review under the correct legal standard. The dissent agreed the lower court was wrong to afford the executive “total immunity and absolute deference” but concluded that the majority’s opinion and remand “swings too far in the opposite direction.”
• On 22 June 2026, the U.S. Supreme Court denied certiorari in a challenge brought by a refrigerant distributor, declining to review the U.S. Court of Appeals for the D.C. Circuit’s August 2025 ruling upholding the EPA’s hydrofluorocarbon (HFC) allowance allocation program under the American Innovation and Manufacturing Act of 2020 (AIM Act). The petition argued that the AIM Act violates the nondelegation doctrine by granting the EPA unbounded discretion to determine which companies may participate in the multibillion-dollar HFC allowance market without providing an intelligible principle to guide that discretion; the D.C. Circuit had rejected that argument, finding that Congress enacted a detailed cap-and-trade program under which the EPA retains discretion to allocate allowances. The denial of certiorari leaves the D.C. Circuit’s ruling in place.
• On 17 June 2026, a divided panel of the U.S. Court of Appeals for the Ninth Circuit affirmed the district court’s ruling in a case involving the Yurok Tribe and a local environmental association, holding that the ESA applies to the U.S. Bureau of Reclamation’s operation of the Klamath Irrigation Project and that water delivery contracts held by Project irrigators do not supersede the Bureau’s ESA compliance obligations. The majority held that because most water delivery contracts “are premised on water availability,” which is constrained by ESA requirements, the Bureau retains discretion to release water from Upper Klamath Lake to maintain in-stream flows for fish, and that the lower court’s declaratory order did not constitute a judicial taking of irrigators’ water rights. The dissent concluded that no statutory provision or contract provides the Bureau with discretion sufficient to trigger the ESA.
• On 11 June 2026, the U.S. District Court for the District of South Carolina vacated the EPA’s guidance terminating the $2.8 billion Environmental and Climate Justice Block Grant Program, finding the decision arbitrary, capricious, and unlawful under the Administrative Procedure Act (APA). The court held that the EPA’s guidance discontinuing the program, which the Inflation Reduction Act directed the agency to keep available through 30 September 2026, was issued for “policy reasons” without lawful justification. The court stopped short of ordering the EPA to resume administering the program, finding such relief impractical given the agency’s disbanding of program staff, and denied a request to extend the program’s statutory award deadline.
• On 10 June 2026, the Carrizo/Comecrudo Nation of Texas and several environmental nonprofits filed suit in the U.S. District Court for the District of Columbia challenging the U.S. Fish and Wildlife Service’s (FWS) approval of the “Boca Chica Land Exchange,” under which a commercial space launch company receives 715 acres of wildlife corridor lands within the Lower Rio Grande Valley National Wildlife Refuge in exchange for 683 acres of private land—one of the largest such exchanges in the refuge system’s history outside Alaska. The complaint’s core allegation is that FWS is rewarding a commercial space launch company for environmental damage it caused: post-explosion surveys documented significant damage to refuge lands and protected bird nests, yet the Service treated those degraded lands as justification for the exchange rather than invoking its enforcement authority. Plaintiffs bring four statutory claims: (1) violation of the National Wildlife Refuge System Improvement Act for failing to demonstrate a net conservation benefit; (2) violation of the National Historic Preservation Act for transferring over 700 acres of the Palmito Ranch Battlefield National Historic Landmark—site of the Civil War’s final battle—without acquiring comparable historic property; (3) violation of NEPA for failing to take the required “hard look”; and (4) violation of the APA.
• On 8 June 2026, the State of North Carolina, through the North Carolina Attorney General acting on behalf of the North Carolina Department of Environmental Quality (DEQ), Division of Water Resources, filed a Verified Complaint and Motion for Preliminary Injunction in Durham County Superior Court, alleging that a chemical distribution company’s chemical storage warehouse in Durham has unlawfully discharged contaminated groundwater into an unnamed tributary to Third Fork Creek, a state-classified drinking water source, in violation of North Carolina water quality law. Following inspections beginning in April 2025, DEQ found compromised chemical storage containers, an inoperable groundwater remediation system, and confirmed violations of surface water and groundwater quality standards. The complaint alleges that the company failed to submit a required corrective action plan by an extended March 2026 deadline and had not done so as of the filing date. The State seeks a preliminary and permanent injunction requiring the company to cease discharges and submit a corrective action plan and site assessment report within 30 days.
• Also on 8 June 2026, the U.S. District Court for the District of Colorado partially enjoined construction of Nebraska Public Power District’s R-Project—a 226-mile, 345-kilovolt transmission line through the Nebraska Sandhills. The court blocked FWS’ invocation of emergency Section 106 compliance procedures under 36 C.F.R. § 800.12(b) and the resulting incidental take permit (ITP), finding that petitioners—including the Rosebud Sioux Tribe—are likely to succeed on their claim that FWS invoked emergency procedures without first determining the R-Project constitutes an “essential and immediate response” to the national energy emergency declared under Executive Order 14156. The court declined to enjoin the broader project, limiting relief to the procedurally defective ITP.
• Also on 8 June 2026, a national environmental nonprofit filed a petition for review in the U.S. Court of Appeals for the D.C. Circuit challenging the EPA’s 9 April 2026 final rule revising methane and volatile organic compound emission standards for the oil and gas sector under the Clean Air Act. The rule loosened flaring and vent gas requirements in response to industry petitions for reconsideration of the 2024 Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (also known as the “Quad-O” rule).
• On 6 June 2026, the U.S. District Court for the District of Columbia vacated IRS Notice 2025-42 in full and remanded to the IRS, holding the Notice arbitrary and capricious under the APA. Notice 2025-42 had eliminated the “Five Percent Safe Harbor.” Under that safe harbor, developers could establish a project’s “beginning of construction” date for Sections 45Y and 48E clean energy tax credit eligibility by paying or incurring at least five percent of project costs, for total wind and large-scale solar facilities specifically, leaving those projects to rely solely on the Physical Work Test ahead of the 4 July 2026 statutory deadline under the One Big Beautiful Bill Act. The court held that the IRS failed to provide a reasoned basis for departing from more than a decade of consistent guidance, did not address serious reliance interests, and did not explain why wind and large-scale solar projects were treated differently from other technology-neutral credit-eligible technologies.
• On 1 June 2026, the U.S. District Court for the Western District of Washington dismissed APA claims brought by a coalition of 23 states, the District of Columbia, and two state agencies challenging the EPA’s termination of the $7 billion Solar for All program established under the Inflation Reduction Act to deploy solar energy in low-income and disadvantaged communities. The court held that the plaintiffs’ request to vacate the termination and reinstate the program amounted to a request for retroactive reinstatement of their grants—a form of contractual relief falling within the exclusive jurisdiction of the Court of Federal Claims under the Tucker Act—and that it therefore lacked jurisdiction to hear the APA claims.

DEI Developments 

• On 12 June 2026, the U.S. District Court for the District of Massachusetts issued a preliminary injunction ordering the U.S. Department of the Interior, the NPS, and the Secretary of the Interior Doug Burgum to restore and reinstall all interpretive materials at NPS sites that were altered, removed, or damaged pursuant to a Secretary’s Order implementing President Trump’s March 2025 executive order, “Restoring Truth and Sanity to American History,” since 20 May 2025. The court set a restoration deadline of 3 July 2026, ahead of the nation’s 250th anniversary, and barred the Trump administration from making any further changes to exhibits at national park sites while the case proceeds, with weekly compliance status reports required.

• On 10 June 2026, a coalition of 20 attorneys general filed suit in the U.S. District Court for the District of Maryland challenging federal agencies’ implementation of Executive Order No. 14398, “Addressing DEI Discrimination by Federal Contractors.” The complaint alleges that federal agencies violated the APA by inserting new contract terms prohibiting contractors from engaging in “racially discriminatory DEI activities” without providing public notice or accepting comments as required by federal procurement law, exceeding their legal authority, and failing to adequately explain how the new requirements differ from existing anti-discrimination law. Federal agencies began adding the new terms to contracts in April 2026, with a deadline to modify existing contracts by 24 July 2026. The coalition, led by the Maryland Attorney General, seeks a declaration that the agencies’ actions are unlawful and an injunction barring enforcement of the new contract terms.

• On 5 June 2026, the City and County of San Francisco filed suit in the U.S. District Court for the Northern District of California against the DOE, challenging new standard terms and conditions the DOE introduced on 12 April 2026 requiring Clean Cities program grantees to certify that they do not operate programs promoting diversity, equity, and inclusion. The complaint alleges that the new conditions exceed the DOE’s statutory authority and violate the APA, the Constitution’s Separation of Powers doctrine, and the Spending Power doctrine. The city, which has participated in the Clean Cities program since 1994 and was awarded $130,000 in program funding on 1 April 2026, contends that the new certification requirement jeopardizes that funding.

• On 4 June 2026, the U.S. Equal Employment Opportunity Commission (EEOC) approved a new National Enforcement Plan (NEP) covering the years 2025 to 2029, terminating the previous plan two years ahead of schedule. The NEP sets out the agency’s enforcement agenda for those years, addressing issues including outreach, public education, technical assistance, enforcement, and litigation. Notably, the NEP directs the EEOC to prioritize intentional discrimination claims over unintentional ones, as directed by Executive Order 14281, and emphasizes challenging DEI-related employment practices, including race- and sex-based quotas, diverse slate policies, diversity-linked compensation, and similar programs at corporations and institutions. Additionally, the NEP elevates as priorities the protection of religious liberty rights and women’s access to single-sex spaces.

International Developments 

• On 17 June 2026, G7 leaders issued a declaration at the Evian Summit committing to reduce dependence on any single supplier outside the G7 for rare earths and permanent magnets to below 60% by 2030—with an ambition to reach 50% as soon as possible—as part of a coordinated effort to diversify critical mineral supply chains away from China, welcoming 195 projects announced since the beginning of 2026 that have reached €64 billion in investment across critical mineral value chains. The leaders established a non-binding G7 Critical Minerals Resilience and Production Alliance, open to like-minded partner countries, to provide a comprehensive platform for cooperation and streamline existing initiatives on critical raw materials. Additional commitments include transparency and traceability pilots beginning with lithium and nickel, with an aim to extend to five new critical minerals each year with particular attention to rare earths, and a joint cooperation mechanism to share data and alerts on future market stress or supply disruptions, facilitated through the International Energy Agency.

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