EU: Commission’s Work Programme sets out key sustainability initiatives for 2027

Post-2030 framework and simplification package (L): The Commission plans to bring forward a new legislative package on the post-2030 energy framework, with a particular focus on simplification. While limited details are provided at this stage, this is likely to be a key initiative shaping the EU's energy and climate policy framework beyond 2030. The Work Programme re-affirms that the EU intends to “stay the course on our climate targets”. In parallel, the Commission will explore the possibility of introducing a Clean Heat Market Mechanism to support the deployment of heat pumps, reduce upfront costs for households and lower exposure to high fossil fuel prices. By way of background, in March 2026, the EU adopted new legislation amending the EU Climate Law to include a new climate target of 90% reduction in greenhouse gases by 2040. That is in addition to previous target of a 55% reduction by 2030. Giving effect to the new 2040 target will require changes to existing legislation – i.e. the post-2030 framework. For more information, see our previous blog post. 

Simplification of the regulatory environment for transport: The Commission plans two initiatives, including a Transport Simplification Package (L) and a proposal relating to ReFuelEU Aviation (L), as part of its broader efforts to simplify the regulatory framework for the transport sector.

European Water Initiative (L/NL): The initiative will focus on improving the management of water resources in response to growing pressures from drought and climate change, while supporting citizens, food security and European industry.

European Heatwave Plan (NL): The Commission plans to develop a European Heatwave Plan to strengthen preparedness for extreme heat, alongside a Climate Insurance Alliance aimed at addressing Europe's climate insurance protection gap and improving climate-risk management (see our previous blog post).

Review of EU nature protection legislation (L/NL): The Commission will review the EU nature protection framework, including the Birds and Habitats Directives and the Natura 2000 framework, to assess whether changes are needed to simplify the framework while ensuring that its environmental objectives are achieved.

Permitting acceleration (L/NL): The Commission will propose further measures to accelerate permitting, particularly for projects in the EU’s strategic interest to attract additional investment. It is unclear at this stage whether this will impact any existing environmental/sustainability rules. 

Review of the CO2 standards for heavy-duty vehicles (L): The Commission will review the existing CO2 emission performance standards for heavy-duty vehicles, with the aim of supporting progress towards climate neutrality while taking into account the competitiveness of the European automotive industry.

European Corporation on Critical Raw Materials (L/NL): The Commission plans to establish a European Corporation on Critical Raw Materials, working alongside the Critical Raw Materials Centre, to strengthen access to materials needed for strategic sectors, including batteries, electric vehicles, chips and defence. The initiative forms part of the Commission's broader efforts to strengthen the resilience of EU supply chains and reduce strategic dependencies.

Review of EU ETS – see our previous blog post. 

Environmental Omnibus – see our EU Omnibus Tracker.

Industrial Accelerator Act – see our previous blog post.

We are also expecting the Commission to publish a proposal for a Circular Economy Act on 2 December 2026 (date TBC) (see our previous blog post). 

The Commission intends to withdraw its proposal for a Green Claims Directive.

By way of background, the Commission published a proposal for a Directive on the substantiation and communication of environmental claims (“Green Claims Directive” or “GCD”) in March 2023. The GCD was intended to complement the Empowering Consumers for the Green Transition Directive (EmpCo) by setting minimum criteria that companies making claims to consumers in the EU about the environmental benefits and performance of their products or services need to meet, as well as minimum criteria for environmental labelling schemes. However, negotiations on the GCD stalled in summer 2025.

 For more information on the draft GCD, see our previous blog posts:

• European Commission publishes proposal for a Green Claims Directive to combat greenwashing
• EU Parliament adopts first reading position on the Green Claims Directive
• EU: Council adopts negotiating position on the Green Claims Directive
• How should companies prepare for the EU’s Green Claims Directive?

The Commission has also published its 2026 Annual Overview Report on Simplification, Implementation and Enforcement, which includes an overview of what the Commission is doing on “gold-plating” – i.e. where Member States go beyond EU legislative requirements when transposing EU legislation into national law and create unnecessary burdens.

In her State of the Union address in September, Commission President Von der Leyen called for a “pact against gold-plating” so that the Commission’s simplification efforts are not wasted (see our previous blog post). 

According to the report published today, the Commission intends for a pact against gold-plating to be signed before the end of 2026. 

This will be supported by a best-practice toolkit and practical transposition guidance, which will be informed by evidence from national authorities, businesses and stakeholders. 

Implementation dialogues and targeted consultations will help identify additional national requirements and divergent interpretations, giving businesses (particularly SMEs and cross-border operators) a voice in the proposed “review and remove” mechanism which the Commission plans to introduce to help Member States identify and address instances of gold-plating. 

The Commission will also explore the use of AI tools to detect gold-plating.