As 2026 begins, our Regulatory team has mapped the key legal and regulatory developments affecting managers of investment funds (including private equity, private credit, hedge and other alternative funds), insurers and other financial institutions operating in the UK, U.S. and EU. We have distilled the main dates into an easy-to-read timeline with brief commentary on
Environmental, Social and Corporate Governance (ESG)
CSRD Agreed: A Major Recalibration of the EU Sustainability Reporting Regime
On 16 December 2025, the European Parliament adopted a significantly streamlined version of the Corporate Sustainability Reporting Directive (“CSRD”). This represents a very significant recalibration of the EU’s sustainability reporting regime.
CSRD’s evolution
The CSRD represents the EU’s flagship framework for mandatory sustainability reporting. Originally designed to apply to a broad range of EU and…
SFDR 2.0 Officially Launched by European Commission
On 20 November 2025, the European Commission officially launched their legislative proposal (“Proposal”) for the updates to the Sustainable Finance Disclosure Regulation (“SFDR”). In a significant departure from the current SFDR disclosure regime, the European Commission proposes a categorisation regime for funds in its place.
The timing remains uncertain but we…
SFDR 2.0 Leaked: Freedom or New Investor Demands for Private Market Sustainability?
On 6 November 2025, the long-awaited “SFDR 2.0” has finally surfaced in a leak and, as many in the market expected, it represents a major reset of Europe Union’s (“EU”) sustainable finance framework. The proposal, still in draft form from the European Commission, aims to simplify the original Sustainable Finance Disclosure Regulation (“SFDR”). Yet for…
European Parliament Rejects “Omnibus” Negotiating Mandate on CSRD and CSDDD Simplification
On 22 October 2025, the European Parliament voted against adopting a negotiating mandate on the European Commission’s Omnibus Directive – a proposal to simplify and streamline sustainability reporting and due diligence obligations under the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD”).
The vote was narrowly…
European Parliament Takes Next Step to Reduce Scope of CSRD
On 8 October 2025, the European Parliament’s Socialists and Democrats (S&D) group ultimately accepted the European People’s Party (EPP)’s position on the Omnibus Directive, which revises the scope of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
Trilogue Negotiations
The next step is for the…
EIOPA Raises Concerns Over Proposed European Union Climate-Reporting Scope Reduction
At the recent Sustainable Finance Conference, EIOPA Chair Petra Hielkema cautioned against the European Commission’s Omnibus proposal to scale back mandatory sustainability disclosures.
Under the proposal, only about 20% of market participants would be required to report, with the remainder left to disclose voluntarily. Hielkema noted that such an approach risks generating incomplete and inconsistent…
CARB Publishes Preliminary List of Companies in Scope of California Disclosure Laws
By Rachel Lowe & Aliza Cinamon on
The California Air Resources Board (CARB) published its preliminary list of companies that may be subject to California’s climate disclosure laws SB 253 (the Climate Corporate Data Accountability Act, which requires U.S.‑based entities doing business in California with over $1 billion in annual revenue to publicly disclose their Scope 1, 2 and 3 greenhouse gas…
New SFDR Clarifications Published by the European Supervisory Authorities
By John Verwey, Rachel Lowe, Sulaiman Malik & Michael Singh on
On 4 August 2025, the European Supervisory Authorities (“the ESAs”) published updated guidance on the application of the Sustainable Finance Disclosure Regulation (“SFDR”) by adding to their Q&A. Below, we break down the areas clarified in the advice and note, with interest, their use of the current European corporate sustainability reporting standards, despite them…
Council of the European Union Agrees Mandate to Streamline CSRD and CSDDD Requirements
By John Verwey, Rachel Lowe, Sulaiman Malik & Michael Singh on
On 23 June 2025, the Council of the European Union (“Council”) endorsed its negotiating mandate on the European Commission’s Omnibus I proposal, which aims to streamline the Corporate Sustainability Reporting Directive ((EU) 2022/2464) (“CSRD”) and the Corporate Sustainability Due Diligence Directive ((EU) 2024/1760) (“CSDDD”). This initiative forms part of a broader EU strategy to reduce regulatory complexity and enhance…