Global: New quick guides and podcasts on sustainability disclosure regimes

We have published a series of quick guides on key sustainability disclosure regimes in the UK, EU, US, Asia, Australia, Middle East and global regimes such as the ISSB and TCFD. We will be updating these guides as and when key developments happen.

We have also produced five bite-sized podcasts on some of the key challenges businesses are facing in terms of navigating the global sustainability disclosure landscape, including interoperability and transition plans.

Click here to explore our quick guides and podcasts.

Global: TNFD publishes first status report showing significant uptake of its disclosure recommendations

In September 2025, the Taskforce on Nature-related Financial Disclosures (TNFD) published a Status Report showing significant initial market uptake of the TNFD’s recommendations and guidance following their release in September 2023:

• 620 organisations from over 50 countries or areas and USD 20 trillion in AUM have publicly committed to getting started with nature-related reporting aligned to the TNFD recommendations;
• Over 500 first- and second-generation TNFD reports have been published;
• 63% of companies and financial institutions surveyed for the report believe their nature-related issues are as significant (or more significant) than climate-related issues to the future prospects of their business;
• 78% of those companies that have already reported have integrated the presentation of their climate and nature reporting; and
• 77% of investors indicated in June that they would like the ISSB to develop a nature disclosure standard building on the TNFD.

For more information on the TNFD, see our Quick Guide.

EU: ESAs 2025 report shows greater effort from firms’ disclosure of principal adverse impacts under SFDR

On 9 September 2025, the European Supervisory Authorities (ESAs) published their fourth annual report on the extent of voluntary disclosure of principal adverse impacts (PAIs) under Article 18 of the Sustainable Finance Disclosure Regulation (SFDR). The ESAs have observed a steady improvement in the quality of the PAI voluntary disclosures at both entity and product level and the report notes an effort from financial market participants (FMPs) to publish more complete information in full compliance with SFDR disclosure requirements, with a general improvement in the quality of information provided. The findings confirm that FMPs within larger multinational groups tend to provide more detailed disclosure, while smaller entities mix information on general ESG or marketing information with their SFDR disclosures. The annex to the report sets out an overview of the good and below average practices, as well as examples of non-compliance. The report also includes recommendations for NCAs to support their supervision of PAI disclosures and for the European Commission to consider ahead of its upcoming review of the SFDR. For more information, see our blog post.

EU: General Court upholds Commission’s classification of nuclear energy and natural gas under EU Taxonomy

On 10 September 2025, the EU General Court dismissed Austria’s challenge against the inclusion of nuclear energy and natural gas in the EU Taxonomy, confirming that these energy sources may qualify as ‘transitional activities’ if they meet strict technical criteria. The General Court also delivered two other judgments on the same day, supporting the Commission’s position on bioenergy and wind power as potential environmentally sustainable activities under the EU Taxonomy. The judgments clarify that the Commission has wide discretion to set technical standards for sustainable finance, and that its approach – based on scientific evidence, public consultation, and existing EU law – has been validated by the General Court. For more information, see our blog post.

UK: FCA proposes clarifications to SDR rules

In its latest quarterly consultation in September 2025, the Financial Conduct Authority (FCA) proposed some helpful clarifications to the SDR rules as follows:

• Clarifying that a manager of an index-tracking fund may meet the rule on selection of assets by investing in assets that meet robust evidence-based sustainability standards, as opposed to “selecting assets” (new ESG 4.2.7(G)(2)).
• Allowing flexibility for product level reports to cover a reporting period of less than 12 months, or to include a period of time during which neither a sustainability label or ESG terms were used. This would serve to give firms greater flexibility to align their reporting of their sustainability reports with the timing of their other regulatory reports. Where firms avail themselves of this flexibility the proposed rule requires them to clearly explain their choice with contextual information in the report (new ESG 5.4.3(1A)).
• Clarifying that firms are not required to produce an on-demand sustainability product report until at least 16 months after the first use of a label or relevant terms (amending ESG 5.5.15R)

The consultation closes on 15 October 2025. For more information on the UK SDR regime, see our Quick Guide.

Global: New SBTi academy and certification process climate target setting

The Science Based Targets initiative (SBTi) has launched the SBTi Academy, a new learning platform to help professionals develop the skills needed to set and deliver science-based climate targets. This includes a new certification process for “SBTi Certified Experts”.

The SBTi’s new e-learning platform is divided into three hubs, catering to different skill levels:

• Onboarding Hub - providing free training at the beginner level;
• Practitioners Hub - providing more advanced premium training for sustainability professionals working across strategy, operations, procurement, and reporting – includes both free and paid modules; and
• Certification Hub - for expert practitioners and consultants looking to showcase their expertise, enabling them to become an SBTi Certified Expert. The SBTi has also published the first ever register of certified science-based target setting experts.

EU: EEA publishes state of environment report flagging significant challenges

On 29 September 2025, the European Environment Agency (EEA) published its State of Environment report with an overall assessment of Europe’s environment, climate, and sustainability outlook across 38 countries. The report acknowledges that Europe has made substantial progress in reducing greenhouse gas emissions, improving air quality, expanding renewable energy, and enhancing recycling and resource efficiency. However, it concludes that the overall condition of the environment across Europe remains critical and continues to face considerable pressure. The assessment points to ongoing declines in biodiversity, driven largely by unsustainable production and consumption patterns. It also notes that water resources are increasingly under stress. The EEA also identifies climate change as a major challenge, with Europe being the fastest-warming continent which is already experiencing severe climate impacts. The EEA warns that the window for meaningful action is narrowing and that the consequences of delay are becoming more tangible. The report highlights that environmental degradation and climate change threaten Europe’s economic competitiveness and long-term prosperity. It concludes that reaching climate neutrality by 2050 will require more effective management of natural resources, strengthened policy implementation, and transformative shifts in production and consumption systems.

EU: What does the 2025 State of the Union say about sustainability?

Each autumn, the President of the European Commission delivers a State of the Union address to the European Parliament to share their vision for the EU and announce major upcoming initiatives. In her State of the Union speech on 10 September 2025, Ursula von der Leyen outlined the Commission’s priorities and flagship projects for the coming year. The address focused on geopolitical challenges and major themes such as security, defence, independence and competitiveness. However, sustainability remained an important element. Von der Leyen placed significant emphasis on the green transition, particularly on the intersection between green and digital transformation. The speech was also marked by a call to “buy European” across a number of sectors such as clean technology and food. More detail on forthcoming initiatives and legislative proposals are expected in October in the Commission’s Work Programme for 2026. For more information on the key sustainability-related topics covered in the State of the Union speech, see our blog post.

EU: Next steps on new 2035 and 2040 climate targets

EU Member States and the European Parliament are currently considering the Commission’s proposal for a new 2040 climate target. Member States are also considering a new 2035 climate target as part of the EU’s Nationally Determined Contribution (NDC) which countries are required to submit to the UN ahead of COP30 in Brazil. However, no agreement has been reached yet and so EU Member States have agreed instead to present the UN with a "statement of intent" which indicates that the EU will try to agree to cut greenhouse gas emissions by 66.25% to 72.5% by 2035 (compared to 1990 level) and intends to submit its final target (NDC) by the start of COP30 in November. EU heads of state are expected to discuss the 2035 and 2040 targets at an EU summit in October. For more information on the Commission’s proposal for a new 2040 climate target, see our previous blog post.

EU: Commission suggests additional one year delay to EU Deforestation Regulation

On 23 September 2025, the Commission wrote to the European Parliament and the Council suggesting an additional one year delay to the application of the EU Deforestation Regulation (EUDR), citing difficulties with the IT system (see letter). The EUDR is currently set to come into force on 30 December 2025. The Commission has not published a draft legislative proposal yet but a proposal is expected at some point in October.

EU: Amendments to Waste Framework Directive to cater for food and textile waste

On 26 September 2025, a Directive amending the 2008 Waste Framework Directive to cater for food and textile waste was published in the Official Journal of the EU and will come into force on 16 October 2025

The new Directive introduces (among other things):

• binding food waste reduction targets, to be met at national level by 31 December 2030; and
• a new extended producer responsibility (EPR) scheme for textiles (such as clothing and accessories, hats, footwear, blankets, bed and kitchen linen, and curtains).

Member States will have 20 months following its entry into force on 16 October 2025 to transpose the rules into national legislation. For more information, see our blog post.

EU: Revision of PFAS restriction proposal

The EU has been taking steps to introduce a universal PFAS restriction under the EU REACH Regulation (the EU’s central chemical regulation framework). A revised restriction proposal was submitted by Member States on 24 June 2025 and was published by the European Chemicals Agency (ECHA) on 20 August 2025. The proposal introduces a broad prohibition on PFAS, with detailed, mostly time-limited derogations and strict compliance requirements. Essential uses, particularly for industrial sectors, will be permitted under proposed exemptions, while consumer applications will generally face stricter controls and shorter transition periods. The restriction proposal applies not only to EU-based manufacturing but also to imported goods. Non-EU companies exporting PFAS-containing products into the EU and the EEA will need to ensure their products remain marketable under the new rules by carefully assessing compliance. For more information, see our blog post.

EU: Impact assessment on revised REACH Regulation receives negative opinion

On 8 July 2025, the European Commission published a package of measures to strengthen the competitiveness of the European chemicals sector which included the European Chemicals Industry Action Plan. The measures envisaged in the Action Plan included adoption of a proposal for a targeted revision of the REACH Regulation by the end of 2025. However, it was reported in the press (see here, subscription required) that on 26 September the European Commission’s internal Regulatory Scrutiny Board (RSB) issued a negative opinion on the impact assessment of this revision. Under the Commission’s own Better Regulation Guidelines, the Commission will now need to resubmit an amended impact assessment for the RSB’s approval. This might jeopardise the Commission’s plans to submit a legislative proposal on a revised REACH Regulation in 2025.

Future of Battery Energy Storage Systems (BESS): UK & Europe Report

Battery storage is key to the energy transition, but investors still face regulatory, permitting, and grid hurdles. Linklaters has published a new report on the Future of Battery Energy Storage Systems (BESS) in UK & Europe 2025 in which we explore the evolving regulatory environment, key market trends, and what’s needed to capture the full value of battery storage, including:

• the impact of European and UK regulation on BESS investment and deployment;
• major challenges facing new projects across jurisdictions; and
• government support schemes, bankability, and paths to greater energy transition resilience

China announces new NDC targets

On 24 September 2025, President Xi Jinping delivered video remarks at the United Nations Climate Change Summit in which he announced China’s new Nationally Determined Contribution (NDC). China’s plan is to cut, by 2035, China’s net greenhouse gas emissions across the entire economy by 7% to 10% from their peak levels expected before 2030. Under the initiative, the proportion of non-fossil energy in primary energy consumption is hoped to reach more than 30% and the total installed capacity of wind and solar power is set at more than six times the 2020 level, aiming for 3.6 billion kilowatts. President Xi emphasised that a green transition remains the “trend of our time” and called for steadfast international co-operation, particularly in clean technology.

China issues new guidelines to expand the national carbon trading market

On 25 August 2025, the General Office of the Communist Party of China Central Committee and the General Office of the State Council jointly issued the Opinions on Promoting Green and Low-Carbon Transformation and Strengthening the Construction of the National Carbon Market (Chinese language) (the Guidelines). The Guidelines provide a roadmap to develop China’s national carbon market. According to the Guidelines, by 2027, the national carbon emission allowance (CEA) trading market is set to cover all major industrial sectors, with the voluntary GHG emission reduction (CCER) trading market expanding to all key areas. By 2030, China aims to establish a national CEA market operating on a cap-and-trade basis with both free and paid allocations, and a transparent and unified national CCER market aligned with international standards. The Guidelines call for invigorating the carbon trading markets by developing diverse carbon market trading products, while improving the regulatory framework and enhancing information disclosure standards. Financial institutions will be encouraged to offer and develop green financial products and services related to carbon emissions rights and CCERs. Banks and other eligible financial institutions will be allowed to participate directly in the national carbon trading market, while access to the CCER market for individuals will gradually be developed.

China rolls out application guidelines for sustainability disclosure standards

On 3 September 2025, China’s Ministry of Finance, together with nine other major government bodies, released the Application Guidelines for the Corporate Sustainability Disclosure Standards—Basic Standards (Trial) (Chinese language) (the Application Guidelines), marking the transition from the development of a framework for sustainability disclosures to the practical implementation of this scheme. Based on the June 2025 draft application guidelines (see our July 2025 ESG Newsletter), the Application Guidelines aim to clarify how to apply the Corporate Sustainability Disclosure Standards (Chinese language) issued in December 2024 (see our February 2025 ESG Newsletter). Notable revisions to the draft issued in June include removal of the “reporting entity” chapter, clearer terminology and user categorisation, further information on the disclosures on the connection between sustainability information and financial reporting, and refined requirements for materiality assessment and scenario analysis. Implementation currently remains voluntary, with mandatory requirements expected in future updates.

China publishes draft amendments to sustainability report guides for listed companies

On 5 September 2025, the Shanghai Stock Exchange, the Shenzhen Stock Exchange and the Beijing Stock Exchange released draft amendments to their Guides for the Compilation of Sustainability Reports (the Draft Amendments), soliciting public comments on new schedules dedicated to pollutant emissions, energy utilisation and water utilisation. The Draft Amendments aim to support implementation of China’s mandatory sustainability reporting guidelines for designated listed companies which became effective from May 2024 (see our May 2024 ESG Newsletter). The Draft Amendments clarify common risks and opportunities associated with three new topics, and serve as a practical “toolbox” or “textbook” to interpret regulatory requirements, without imposing additional mandatory disclosure obligations. The Draft Amendments aim to enhance the environmental management practices for listed companies and promote the development of a low-carbon, sustainable market ecosystem in China. The consultation period ended on 19 September 2025.

China unveils financial measures to accelerate forestry sector development

On 15 August 2025, the People's Bank of China, together with the National Financial Regulatory Administration and the National Forestry and Grassland Administration, issued the Notice on Financial Support for High-Quality Forestry Development (Chinese language) (the Notice). The Notice introduces 15 targeted measures to “leverage financial strength” in the country’s forestry industry, calling for innovation in forest rights mortgage lending, expanded scope of mortgageable forest rights, legally compliant loan term extensions, and overall improvements in loan quality, quantity, and accessibility. The Notice refers measures to promote carbon sink finance, the use of digital technologies for credit assessment and risk control, and to expand direct financing channels for forestry-related enterprises. The Notice also advocates streamlined loan approvals, developing unified valuation standards, and new insurance products such as index, income and carbon sink insurance.

Hong Kong SAR: HKMA publishes “Phase 2A prototype” of its sustainable finance taxonomy for public consultation

On 8 September 2025, the Hong Kong Monetary Authority (HKMA) launched a public consultation on Phase 2A prototype of the Hong Kong Taxonomy for Sustainable Finance (the Phase 2A Taxonomy). The Phase 2A Taxonomy builds on the publication of Phase 1 of the Hong Kong Taxonomy in May 2024 (see our previous blog post) by adding new sectors, economic activities, and transition elements. It also introduces climate change adaptation as an environmental objective, being one of the first few taxonomy frameworks globally to address this issue. For more information, see our blog post.

Hong Kong SAR: HKMA launches a consultation to update its supervisory guidance on stress-testing for banks

On 28 August 2025, the Hong Kong Monetary Authority (HKMA) issued a letter to consult with the banking industry on proposed revisions to the Supervisory Policy Manual (SPM) module IC-5 on “Stress-testing”, which was last updated in 2012. Among other things, the updated framework requires authorised institutions to incorporate climate-related risks into their stress scenarios. The consultation closes on 30 September 2025.

Hong Kong SAR: HKEX signs agreement with regional exchanges to advance carbon market ecosystem in the Greater Bay Area

On 23 September 2025, the Hong Kong Exchanges and Clearing Limited (HKEX) announced it had signed a memorandum of understanding (MoU) with the Guangzhou Emissions Exchange (CEEX), Shenzhen Green Exchange (SGE) and Macao International Carbon Emission Exchange (MEX) to accelerate the development of the carbon market and green finance ecosystem across the Greater Bay Area (GBA). The aim is to foster deeper collaboration, knowledge sharing, and market connectivity between mainland China’s mandatory and voluntary carbon markets and international platforms.

Hong Kong SAR: HKEX publishes “Carbon Credits: A Buyer’s Guide”

On 10 September 2025, the Hong Kong Exchanges and Clearing Limited (HKEX) published Carbon Credits: A Buyer's Guide (the Guide) which explains the mechanisms behind carbon credits and shares practical insights into how corporates can shortlist carbon projects and ultimately select carbon credits for their needs (see HKEX press release). The Guide covers two stages – the first being “project shortlisting” focusing on a series of practical steps companies can take to first shortlist carbon projects and the second stage being “carbon credit selection” based on two main components: standard and vintage.

Hong Kong SAR: Financial Services Development Council publishes report on impact investing in Hong Kong

On 10 September 2025, the Financial Services Development Council (FSDC) published a research report on “Hong Kong: Showcasing how Impact Capital Makes a Difference”. According to FSDC’s press release, the report provides an “analysis of Hong Kong's maturing ecosystem, snapshotting how strategic visions are transforming into tangible, real-world impact.”

Singapore: Green Investments Partnership achieves first close under the FAST-P initiative

On 8 September 2025, the Monetary Authority of Singapore (MAS) announced that the Green Investments Partnership (GIP) (a blended finance partnership under Singapore’s Financing Asia Transition Partnership (FAST-P) initiative (see our February 2024 ESG newsletter)) has achieved its first close with US$510 million of committed capital from global and regional private, public and philanthropic institutions. GIP aims to bridge Southeast and South Asia’s climate finance gap by funding green and sustainable infrastructure projects and is the first fund under the FAST-P initiative to achieve first close.

Singapore enters into implementation agreement on carbon credits collaboration with Vietnam

Singapore signed its ninth implementation agreement on carbon credits collaboration under Article 6 of the Paris Agreement with Vietnam on 16 September 2025 (following agreements with Papua New Guinea, Ghana, Bhutan, Chile, Peru, Rwanda, Paraguay and Thailand). As part of the agreement, Singapore is committed to channelling the value equivalent to 5% share of proceeds from authorised carbon credits towards climate adaptation measures in Vietnam. It also commits to having 2% of the correspondingly adjusted carbon credits authorised under the Implementation Agreement cancelled at first issuance. These carbon credits that are cancelled cannot be sold, traded, or counted towards any country's emission targets. On 16 September 2025, Singapore’s government also announced contracts to purchase 2.18 million tonnes of nature-based carbon credits from four projects in Ghana, Paraguay, and Peru.

Thailand proposes phased rollout of ISSB-aligned climate reporting framework for listed companies

On 22 September 2025, the Securities and Exchange Commission of Thailand (SEC) published the “Draft Notifications and Relevant Documents regarding the Regulatory Amendment related to the Sustainability-Related Information Disclosure Requirements of the Listed Companies towards the International Sustainability Standards Board Standards (ISSB Standards)” (the Draft Amendment). The Draft Amendment follows the consultation on the guidelines for enhancing sustainability disclosures in line with the ISSB Standards for Thai listed companies issued by the SEC in November 2024 (see our December 2024 ESG newsletter).

Under the Draft Amendment, mandatory climate-related disclosures (which the SEC is considering adopting the ISSB Standards by referencing the IFRS S1 and S2) will initially apply to those listed companies categorized in the SET 50 Index (being, the 50 largest companies by market capitalisation with high trading liquidity on the Stock Exchange of Thailand (SET)) for the 2026 fiscal year, which shall disclose the required information in 2027. This requirement will be extended to those listed companies categorized in the SET100 Index in the 2027 fiscal year, and to all SET-listed companies by 2029. By 2030, reporting obligations will also include issuers listed on Thailand’s Market for Alternative Investment (MAI) – which predominantly comprises small and medium-sized enterprises and growth-stage businesses – as well as Real Estate Investment Trusts listed on the SET, Infrastructure Funds, Infrastructure Trusts listed on the SET, and Property Funds, while excluding those listed on the LiVE Exchange (or LiVEx, an exchange for qualified small and medium-sized enterprises and start-ups). Additionally, listed companies will be required to report Scope 1 and Scope 2 emissions using recognised international standards such as the Greenhouse Gas Protocol, and these disclosures must be verified that the emission data is in line with internationally accepted assurance standards as specified by the SEC.

Federal and State Agency Actions

On 24 September 2025, the California Air Resources Board (CARB) released a list of over 3,000 entities it believes fall within the scope of the state’s climate disclosure laws - the California Corporate Greenhouse Gas Reporting Program (SB 253) and Climate Related Financial Risk Disclosure Program (SB 261). SB 253 requires companies with annual revenues exceeding $1 billion and doing business in California to annually disclose their scope 1, 2 and 3 greenhouse gas (GHG) emissions for the prior fiscal year, while SB 261 requires companies with annual revenues over $500 million and doing business in California to publish climate-related financial risk reports every other year. CARB has also published a draft checklist to aid companies preparing to report under SB 261, the first due date for which is 1 January 2026. For more information, see our blog post. For further details on the California climate disclosure regimes, see our Quick Guide.

On 22 September 2025, the U.S. Environmental Protection Agency (EPA) proposed a new rule to revise the process for conducting risk evaluations for chemicals in commerce adopted by the Biden administration in 2024 pursuant to the Toxic Substances Control Act (TSCA). The proposed rule loosens chemical health risk evaluations by removing provisions in the 2024 final rule that require EPA to consider every condition of use and every exposure pathway based on reasonably available information when conducting a chemical health risk evaluation. The proposed rule is designed to speed up the review process while still protecting human health and the environment, according to a press release issued by EPA.

On 12 September 2025, the EPA proposed repealing its long-standing Greenhouse Gas Reporting Program (GHGRP), which has required power plants and fossil fuel suppliers to report greenhouse gas emissions on an annual basis since 2009. The GHGRP currently requires more than 8,000 facilities and suppliers across 47 source categories to report GHG emissions data. If finalized, the proposal would remove reporting obligations for all sectors except petroleum and natural gas systems. Even within that sector, reporting for natural gas distribution would end permanently, while reporting for other segments would be deferred until 2034. In a press release issued the same day, the EPA stated that the reporting requirements are costly and do not significantly benefit human health or the environment, estimating that repealing them would save companies $303 million per year until 2033.

On the same day, the Federal Energy Regulatory Commission (FERC) announced it is ending its ongoing review of its gas infrastructure approval policy, affirming that the existing 1999 Certificate Policy Statement remains effective. This decision comes after the U.S. Department of Energy (DOE)—supported by pipeline companies and industry groups—requested termination of the proceeding that began in 2018. FERC noted that project reviews will continue on a case-by-case basis, as has been the approach since the proposed revision was withdrawn in 2022.

On 11 September 2025, the EPA asked the U.S. Court of Appeals for the D.C. Circuit to vacate parts of its drinking water standards for several "forever chemicals" finalized in 2024 during the Biden administration, arguing that it had erred by simultaneously proposing and finalizing regulations for three (3) types of per- and polyfluoroalkyl substances (PFAS) without adequate public comment. The EPA also sought to rescind its use of a hazard index approach for another PFAS variant, citing procedural issues that deprived the public of sufficient opportunity to participate in decision-making. The EPA request comes in response to legal challenges raised by water utilities and chemical industry groups, who argued that the rule failed to meet requirements under the Safe Drinking Water Act.

On 4 September 2025, the EPA outlined a deregulatory agenda for the coming months, signaling plans to revisit or roll back several Biden-era rules on water, climate change, and chemical regulation. Detailed in the White House's semiannual regulatory agenda, the EPA’s priorities include rescinding regulations on greenhouse gas and mercury emissions from power plants, altering the scope of federal authority under the Clean Water Act with proposals, and revoking endangerment findings for emissions related to motor vehicles and aircraft. The EPA also plans to extend compliance deadlines and narrow the scope for new drinking water standards covering PFAS, and to revise requirements for PFAS reporting and recordkeeping under the Toxic Substances Control Act. Critics argue that these measures represent an unprecedented rollback of key regulatory protections affecting public health and environmental safety.

On the same day, various federal agencies announced proposals to scale back environmental, social, and governance (ESG) rules. As detailed in the White House's semiannual regulatory agenda, the Department of Labor (DoL) intends to replace existing guidance, which permits retirement fund managers to consider ESG factors, with a new regulation restricting decisions to purely financial considerations rather than advancing social objectives. The draft rule is anticipated for adoption next year, as noted in the DoL’s Employee Benefits Security Administration rulemaking agenda. This follows the DoL’s statement earlier in 2025 regarding its plans to rescind a prior rule allowing ESG-related investment decisions. In parallel and as also detailed in the White House's semiannual regulatory agenda, the Securities and Exchange Commission is developing a rule to standardize disclosure practices and provide clearer access to material information for shareholders, after confirming it will not defend its paused climate disclosure regulation against legal challenges.

In late August 2025, the DOE issued emergency orders to extend operations at key fossil fuel-fired power plants in Michigan and Pennsylvania, both of which were originally scheduled to close earlier this year. These actions were taken pursuant to Section 202(c) of the Federal Power Act in response to concerns about electricity grid reliability and rising energy demand, but have drawn legal challenges from environmental groups questioning the necessity of the extensions.

• On 27 August 2025, the DOE Secretary ordered a Pennsylvania-based oil / natural gas-fired power plant to remain open until 26 November 2025, further extending the plant’s operation beyond its planned May closure amid continued concerns over grid reliability in the mid-Atlantic region. Environmental groups are contesting the order, arguing that the cited energy shortfall risks do not exist.
• On 20 August 2025, the DOE extended its emergency order requiring a Michigan-based coal-fired power plant to remain open until 19 November 2025, citing ongoing regional electricity shortages and increased energy demand, particularly due to the growth of energy-intensive data centers. Environmental groups are contesting this order as well, echoing similar legal challenges to the DOE’s recent extension of the Pennsylvania plant’s operations described above.

On 14 August 2025, the U.S. Fish and Wildlife Service (FWS) announced plans to rescind its 2024 Biden-era Endangered Species Act (ESA) rule that it explained automatically imposed the strictest protections on all listed plants and animals, regardless of threat level. In filings with a Montana federal court, FWS indicated it intends to reverse the so-called blanket 4(d) rule, which permits land use controls on private property for any species protected under the ESA. This proposed recission is being challenged in court by environmental organizations, who claim FWS overreached its authority. FWS has drafted a proposed rule to eliminate the blanket approach for new threatened species, which is pending federal review, and expects to publish it by October.

In late August and September 2025, actions by the Trump administration triggered a series of significant federal interventions in the offshore wind industry, including the cancellation of major project approvals, redirection of funding, and heightened litigation. These developments have sparked legal battles between states, developers, and federal agencies.

• On 15 September 2025, the Trump administration filed a motion with the U.S. District Court for the District of Maryland to vacate the Department of Interior’s (DOI) Bureau of Ocean Energy Management’s (BOEM) approval of US Wind’s Maryland Offshore Wind Project’s Construction and Operation Plan (COP), given BOEM’s recent ongoing reevaluation of the COP pursuant to President Trump’s executive memorandum issued earlier this year. The motion has been filed in the context of an underlying dispute filed by various challengers in 2024 seeking to challenge the underlying COP approval issued by the Biden administration.
• On 4 September 2025, Connecticut and Rhode Island, alongside a Danish energy company, filed lawsuits against BOEM’s 22 August 2025 order which halted a nearly completed offshore wind project off Rhode Island, arguing the stop work order was unlawful and lacked justification. Both the states and the energy company allege that federal agencies disregarded established procedures and violated the Administrative Procedure Act, despite the offshore wind project securing all federal and state permits after a decade-long review by multiple federal agencies. On 22 September 2025, the District Court granted a preliminary injunction in favor of the energy company of BOEM’s 22 August 2025 stop work order, allowing the project to proceed pending the outcome of the underlying litigation.
• On 3 September 2025, BOEM filed an unopposed motion with the U.S. District Court for the District of Columbia, seeking to file a motion to vacate its COP approval of an offshore wind project off Massachusetts. BOEM plans to revoke the July 2024 COP approval, following lawsuits alleging the project failed to sufficiently consider impacts on marine life and island views.
• On 29 August 2025, the U.S. Department of Transportation cancelled $679 million in federal funding for 12 offshore wind projects approved under the Biden administration, instead redirecting these funds to support the shipbuilding industry.

Presidential Actions

On 28 August 2025, President Trump signed an executive order expanding his previous directive cancelling collective bargaining rights for employees at several federal agencies. The President’s 27 March 2025 order invoked a rarely used portion of the Civil Service Reform Act of 1978 to suspend collective bargaining for national security purposes. The new order extends this prohibition to the National Aeronautics and Space Administration, the U.S. Agency for Global Media, the National Weather Service and the National Environmental Satellite, Data, and Information Service (both of which are within the National Oceanic and Atmospheric Administration), the Bureau of Reclamation’s hydropower program, the International Trade Administration, and the Patent and Trademark Office’s commissioner of patents office.

Anti-ESG Actions

On 3 September 2025, a U.S.-based investment management corporation lost a mandate worth $17 billion with one of the largest pension funds in the Netherlands due to concerns over the corporation’s record on sustainability issues and lack of any explicit condemnation of the Trump administration’s comprehensive anti-net zero policies. A spokesperson for the pension fund stated that they have been developing a new investment strategy where financial performance, risk, and sustainability are weighted equally within the framework of a total portfolio approach. This follows a recent trend of other overseas asset owners voicing discontent with U.S.-based money managers that have retreated from climate alliances amid the Trump administration’s recent policies.

DEI Developments and Litigation

On 18 September 2025, the U.S. Department of Justice’s Civil Rights Division (CRD) announced that it will investigate the city of Austin, Texas, for illegal employment practices that discriminate based on race, sex, color, and national origin. The investigation targets a plan promoted by the city’s Office of Equity and Inclusion, which articulates how the city can “work using a racial equity lens.” This follows reports that CRD has recently begun issuing Civil Investigative Demands targeting employers’ diversity, equity, and inclusion (DEI) initiatives.

On 8 September 2025, the Supreme Court of the United States (SCOTUS) lifted a temporary injunction that had restricted broad immigration stops in Los Angeles. This followed a July lower court ruling, which held that immutable factors—like appearance and accent—are not independently sufficient grounds to question individuals under immigration law. Siding with the majority, Justice Brett Kavanaugh wrote that the federal government “demonstrated a fair prospect” that the high court would reverse if asked to rule on the merits, finding that they lacked standing to challenge the government’s enforcement actions.

For recent litigation updates, see our most recent ESG Disputes Bulletin.

ESG Disputes Bulletin – read our newsletter

EFRAG’s proposed amendments to ESRS: a detailed overview: read our blog post

Spain requires large companies to report their carbon footprints and develop GHG emissions reduction plans: read our blog post

Singapore: extended timelines for most climate reporting requirements for listed and large non-listed companies: read our blog post