ESG Policies and Regulations Update March 2024
The following details framework updates, and their implications, that occurred in March, as well as highlighting some key updates and releases to be aware of in the coming few years. Frameworks such as those explored in this report can help stakeholders understand how an organisation manages risks and opportunities around such sustainability issues. Often used as a communication tool, it can play an important role in demonstrating the sincerity of a company’s actions as well as ensuring good governance.
Monthly update
After the CSDDD’s multiple delays to EU member state voting in February, progress has been announced for the framework. Additionally, March also saw some long-awaited updates from SEC, after its own delays to the release of its climate disclosure rule.
Framework | Update | Date |
---|---|---|
SEC’s climate rule | Climate disclosure rules agreed by the US Securities and Exchange Commission | 6 March 2024 |
CSDDD | EU member states have reached an agreement to progress the CSDDD. | 15 March 2024 |
SBTi | Net Zero Standard for businesses has been updated | 19 March 2024 |
Implications
SEC’s Climate Disclosure Rule
The US Securities and Exchange commission approved the final climate disclosure rule on 6 March. It will initially apply to only large, listed entities that already post filings through the SEC, which is estimated to be around 10,000 organisations.
The rule mandates public companies to annually report their greenhouse gas emissions and climate-related risks that are likely to have material impact on their business by financial year 2025. Organisations in scope are also required to disclose how they are managing those risks and any related corporate targets.
Corporate Sustainability Due Diligence Directive (CSDDD)
The CSDDD will impose mandatory human rights and environmental due diligence and transition plan requirements on firms in scope.
EU member states have finally reached an agreement to progress the CSDDD. The version approved was a stripped-back version of the Directive; it is likely to be enshrined in law before the European elections later this year. Its scope has been narrowed to organisations with 1,000 or more employees and with an annual turnover of €450m or more.
Science Based Targets initiative (SBTi)
The SBTi is a global body enabling businesses to set ambitious emissions reductions targets in line with the latest climate science.
SBTi have unveiled minor updates to its Corporate Net Zero Standard. This provides clarify on the scope of the Standards and how businesses can certify. This Standard requires businesses to commit to reducing absolute emissions across all scopes by at least 90% by 2050 or sooner. The revisions added updated information on the target validation process, as well as clarifying which businesses can use the Standard as usual and which can use a more lenient pathway for SMEs.
Another change has been the embedding of key points on how businesses can design and implement strategies to go beyond value chain mitigation, engaging in activities that accelerate systems change for the global net-zero transition even if they do not reduce a company’s own value chain emissions.
These updates will affect those organisations considering or about to embark on their net-zero target setting journey.
Horizon Scanning
Date expected | Framework | Description |
---|---|---|
April 2024 | ISSB | Digital Taxonomy release expected |
May 2024 | UK SDR | Anti-greenwashing rule and guidance comes into force on 31 May |
June 2024 | TCFD | FCA ESG Rules: TCFD disclosures relating to Financial Year 2023 to be finalised |
June 2024 | UK SDR | First elements of the new rules (excluding anti-greenwashing rule) to come into force – at the earliest |
July 2024 | ESRS | Anticipated adoption of the second draft of ESRS |
July 2024 | UK SDS | Secretary of State for Business and Trade will consider the endorsement of the IFRS Sustainability Disclosure Standards, to create the UK SDS |
July 2024 | UK SDR | Firms can begin to use labels, with accompanying disclosures from 31 July |
July 2024 | TPT | TPT’s mandate extended until at least 31 July, in order to support the Transition Finance Market Review |
December 2024 | UK SDR | Naming and marketing rules come into force, with accompanying disclosures, from 2 December |
2024 | CSRD | Due to supersede NFRD in 2024. Large companies already subject to NFRD must begin reporting on the fiscal year 2024. Drafting of sectoral-ESRS. |
2024 | CSDDD | Application of CSDDD to certain EU and non-EU companies expected to begin at some stage in 2024 |
2024 | GHG Protocol | Expected to release drafts of revised text |
January 2025 | CSRD | Expected application of CSRD to large EU reporting. Sustainability reporting in 2026 for Financial Year 2025 |
June 2025 | UK ETS | The window for operators of installations to apply for free allocation, or to be in the schemes for hospital or small emitters or for ultra-small emitters, in the 2026-2030 allocation period is 1 April – 30 June 2025 |
October 2025 | UK ETS | Hospitals or small emitters and ultra-small emitters for the 2026-2030 allocation period must be published by 17 October 2025 |
December 2025 | UK SDR | Ongoing product-level and entity-level disclosures for firms with AUM>£50bn, from 2 December |
2025 | GHG Protocol | Final standards and guidance to be released |
2025 | UK SDS | Suite of KPIs will need to responded on from 2025 onwards |
January 2026 | CSRD | Expected application of EU CSRD to listed SMEs (may affect a small number of portfolio companies) |
February 2026 | UK ETS | Date before which the allocation table for the 2026-2030 allocation period must be published is 28 February 2026 |
December 2026 | UK SDR | Entity-level disclosure rules extended to firms with AUM>£5bn, from 2 December |
January 2028 | CSRD | Expected application of EU CSRD to non-EU companies, reporting in 2029 for Financial Year 2028 |
Funding
In its Autumn Statement 2022, the UK Government announced a new, long-term commitment to enhance energy efficiency, aiming to drive down costs for households, businesses, and the public sector with the end goal being a 15% reduction in the UK’s final energy consumption from buildings and industry by 2030 compared to 2021 levels.
This commitment took the form of new government funding worth £6 billion being made available from 2025 to 2028. These funds have recently been earmarked, in a government press statement on December 18, 2023, for various schemes aimed at delivering energy efficiency assistance to businesses and homes throughout the United Kingdom. Some of these schemes are new, while some are existing schemes that have been allocated more funding.
Scheme | Allocation | Description | Years of funding in the next spending review period |
---|---|---|---|
Boiler Upgrade Scheme | £1.545bn | Replacing fossil fuel heating systems | 2025/2026 – 2027/2028 |
Heat Pump Investment Accelerator | £15m | Bringing forward investment in the UK heat pump manufacturing supply chain | 2025/2026 |
New £400m energy efficiency grant | £400m | For households in England to make changes such as bigger radiators or better insulation | 2025/2026 – 2027/2028 |
New local authority retrofit scheme | £500m | Supporting low-income and cold homes with measures such as insulation | 2025/2026 – 2027/2028 |
Social Housing Decarbonisation Fund | £1.253bn | Supporting social homes to be insulated or retrofitted | 2025/2026 – 2027/2028 |
Green Heat Network Fund | £485m | Helping homes and buildings access low carbon, affordable heating | 2025/2026 – 2027/2028 |
Heat Network Efficiency Scheme | £45m | Improving around 100 existing heat networks | 2025/2026 – 2027/2028 |
Public Sector Decarbonisation Scheme | £1.17bn | Providing grants for public sector bodies to fund heat decarbonisation and energy efficiency measures | 2025/2026 – 2027/2028 |
Industrial Energy Transformation Fund | £225m | Continuing to help businesses transition to a low-carbon future | 2025/2026 – 2027/2028 |
Industrial Energy Efficiency and decarbonisation support | £410m | Further details to be announced in due course | 2025/2026 – 2027/2028 |
Sustainability abbreviations
CSDDD – Corporate Sustainability Due Diligence Directive
CSRD – Corporate Sustainability Reporting Directive
ESRS – European Sustainability Reporting Standards
GHG Protocol – Greenhouse Gas Protocol
GRI – Global Reporting Initiative
ISSB – International Sustainability Standards Board
SBTi – Science-Based Targets Initiative
TCFD – Taskforce for Climate Related Disclosure
UK ETS – UK Emissions Trading Scheme
UK SDR – Sustainability Disclosure Requirements
UK SDS – Sustainability Disclosure Standards