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Sustainability

Sustainable Finance Policy and Regulation Round-up

UK Sustainability Reporting Standards (SRS) released alongside EU Green Bond Standard clarification

Our Sustainable Finance Policy and Regulation round‑up highlights the latest developments shaping the market.

Key updates at a glance

UK 

1. UK Government releases UK Sustainability Reporting Standards (UK SRS)
2. EPC (Energy Performance Certificate) Forum on energy performance reform delayed to H2 2027
3. HM Treasury launches a consultation on UK Carbon Border Adjustment Mechanism (CBAM)
4. UK Government publishes Q1 progress on Industrial Strategy
5. UK Transition Finance Council (TFC) unveils its first year-end progress report
6. UK government publishes security assessment on global biodiversity loss and ecosystem collapse

EU

7. EU Commission publishes correction to previous FAQ on EU Green Bond Standard (EU GBS)
8. European Commission announces revisions to EU Taxonomy technical screening criteria
9. Update on the EU Industrial Accelerator Act (IAA)
10. EBA launches consultation on simplifying the credit risk framework
11. ECB study finds causal link between climate disasters and the cost of debt

Recent UK & EU policy developments — and their implications for issuers

Top Story | UK Government releases UK Sustainability Reporting Standards (UK SRS), establishing a voluntary framework for corporate sustainability disclosures

The UK SRS, published [1] in February 2026, are aimed at enabling companies to disclose sustainability and climate-related financial risks and opportunities, aligned with internationally recognised reporting frameworks.

Scope and timelines:

Currently, compliance with the UK SRS is voluntary, but mandatory application is on the radar of the UK Government and the FCA

The standards specifically target: 

  • Listed companies: the FCA is consulting on making the standard mandatory under UK Listing Rules – replacing the current TCFD framework, with phased implementation from 1 January 2027. 
  • Large private companies: Government consultation is expected during 2026 on extending mandatory reporting to UK’s large private companies (thresholds TBC) via the Companies Act 2006.

Interoperability with other frameworks:

  • ISSB‑aligned (International Sustainability Standards Board): UK SRS is closely aligned with ISSB standards (IFRS S1 and S2), with S1 covering overarching sustainability disclosures and S2 focused on climate‑related risks and opportunities
  • Built on TCFD (Task Force on Climate related Financial Disclosures): The standards retain the familiar TCFD structure - governance, strategy, risk management, and metrics & targets -supporting continuity for existing reporters.

What this means for Treasury teams:

  • Cost of capital: Companies must assess how sustainability-related risks cash flows and long - term financial viability. Material impacts can influence cost of capital. 
  • Funding strategy and reporting: Entity level sustainability information is seen as critical when assessing company eligibility for sustainable & transition finance – sustainability profiles (based on company disclosures) will play a huge role in screening and assessment processes for investments. 
  • Funding the transition and resilience: Treasurers should work closely with sustainability and risk teams to embed carbon budgets, climate transition plans, and the funding of physical climate risk mitigation (e.g. asset resilience, insurance, and adaptation capex) into financial planning, ensuring both decarbonisation commitments and climate resilience investments are credibly financed. 
  • Investor expectations: Growing investor alignment with ISSB standards makes high‑quality, consistent disclosures critical for maintaining market access and confidence.

Top Story | EU Commission publishes correction to their previous FAQ on EU GBS

The European Commission has issued a correction to its EU Green Bond Standard (EuGB) FAQ, confirming that CapEx (Capital Expenditure) incurred before bond issuance may be eligible.

Article 4 (1)(b) of the EuGB Regulation and look back CapEx

Previous interpretation

This means that only new CapEx incurred after the issuance of the EuGB is eligible

New clarification

  • The Commission now clarifies that, as Article 4(1)(b) does not prohibit a look back period, pre issuance CapEx can qualify.
  • Eligibility remains conditional on alignment with Article 3 of the EU Taxonomy (environmentally sustainable economic activities).
  • Issuers are expected to follow established market practice and investors’ expectations regarding the refinancing of historical CapEx.

 

What this means for Treasury teams:

  • Past CapEx can be refinanced through EuGBs, subject to Taxonomy alignment.
  • Issuers are expected to follow established market practice and investor expectations when refinancing historical CapEx.
  • The clarification improves flexibility and may broaden the pool of eligible assets for EU Green Bond issuance.

Further UK developments

EPC Forum to reform buildings’ energy performance regime postponed to late 2027

The UK government announced reforms to its Energy Performance of Buildings (EPB) regime [3], including a consultation on Energy Performance Certificates (EPCs) launched in December 2024.

A partial response to the consultation was published, confirming plans to introduce four new headline metrics on new-style domestic EPCs – transitioning from a single headline metric to move to multi-metric EPCs, retain existing headline metric on non-domestic EPCs, a 10-year validity period and update on buildings where EPCs will be required post-reform.

Following industry feedback, the EPC reform intended to be published by October 2026 will be delayed until H2 2027, with a revised launch date and implementation plan shared by mid-2026.

HM Treasury launches a policy summary and consultation on UK CBAM

Updates on the UK Carbon Border Adjustment Mechanism (CBAM) [4], including draft secondary legislation and consultation (closed on 24 March 2026) were issued. It will apply to UK (including NI) imports of aluminium, cement, fertilisers, hydrogen, iron & steel. The policy summary outlines:

  • Scope: in scope commodity codes and limited exclusions.
  • Treatment of imports: taxable point (i.e., where CBAM charges arise), rules for special customs procedures, and possible exemptions.
  • Liability: use of actual emissions vs defaults, weight determination, CBAM rate selection, and Carbon Price Relief (CPR) for qualifying foreign carbon pricing.
  • Administration: registration for importers of >£50,000/year of CBAM goods, record keeping, returns, payments, and repayments. Businesses must retain detailed records (codes, weights, dates, emissions, CPR evidence) for six years.

Following final responses by 24 March 2026, a second tranche is expected in spring 2026, with final secondary legislation later in 2026 ahead of full CBAM implementation from 1 January 2027.


UK Government publishes Q1 progress on Industrial Strategy

The UK Government’s 10-year plan to significantly increase business investment in 8 growth-driving sectors by making it quicker and easier for businesses to invest and providing them with the stability needed for long-term investment decisions. Q1 of 2026 has seen material developments in line with the UK Government’s Industrial Strategy, some highlights are:

  • Major package of industrial sector commitments set out in the Northern Growth Strategy: Includes the City Investment Fund backing a pipeline of priority projects drawn from Local Growth Plans.
  • Increased access to finance: UK Export Finance agrees £11bn lending package with 5 leading UK banks.
  • National Wealth Fund 5-year strategic plan: £27.8bn to be deployed, with a strong focus on crowding in investment into clean-energy.

 

Transition Finance Council (TFC) unveils its first year-end progress report

TFC, established in February 2025, published its first year-end report [5] giving an overview of the progress made by the TFC on the publications launched through the year:

  1. Transition Finance Guidelines (TFG): Voluntary draft guidelines that enable capital providers to identify credible transition finance opportunities at entity-level. These are intended for unlabelled general equity and debt finance to help assess the credibility of a company’s transition planning and implementation and qualify investment as transition finance.
  2. The Finance Playbook: Developed along with the Net Zero Council, the playbook offers practical guidance on integrating robust finance plans within sector transition plans and technology scale-up roadmaps.

Looking ahead:
In its second year, the TFC will shift from framework development to implementation and market engagement, focusing on:

  • International alignment – positioning TFG as a global reference point
  • Industry adoption – supporting companies and investors to apply the guidelines in practice
  • Market development – accelerating transition‑aligned financial instruments and investment
     

Further UK developments

EPC Forum to reform buildings’ energy performance regime postponed to late 2027

The UK government announced reforms to its Energy Performance of Buildings (EPB) regime [3], including a consultation on Energy Performance Certificates (EPCs) launched in December 2024.

A partial response to the consultation was published, confirming plans to introduce four new headline metrics on new-style domestic EPCs – transitioning from a single headline metric to move to multi-metric EPCs, retain existing headline metric on non-domestic EPCs, a 10-year validity period and update on buildings where EPCs will be required post-reform.

Following industry feedback, the EPC reform intended to be published by October 2026 will be delayed until H2 2027, with a revised launch date and implementation plan shared by mid-2026.

HM Treasury launches a policy summary and consultation on UK CBAM

Updates on the UK Carbon Border Adjustment Mechanism (CBAM) [4], including draft secondary legislation and consultation (closed on 24 March 2026) were issued. It will apply to UK (including NI) imports of aluminium, cement, fertilisers, hydrogen, iron & steel. The policy summary outlines:

  • Scope: in scope commodity codes and limited exclusions.
  • Treatment of imports: taxable point (i.e., where CBAM charges arise), rules for special customs procedures, and possible exemptions.
  • Liability: use of actual emissions vs defaults, weight determination, CBAM rate selection, and Carbon Price Relief (CPR) for qualifying foreign carbon pricing.
  • Administration: registration for importers of >£50,000/year of CBAM goods, record keeping, returns, payments, and repayments. Businesses must retain detailed records (codes, weights, dates, emissions, CPR evidence) for six years.

Following final responses by 24 March 2026, a second tranche is expected in spring 2026, with final secondary legislation later in 2026 ahead of full CBAM implementation from 1 January 2027.


UK Government publishes Q1 progress on Industrial Strategy

The UK Government’s 10-year plan to significantly increase business investment in 8 growth-driving sectors by making it quicker and easier for businesses to invest and providing them with the stability needed for long-term investment decisions. Q1 of 2026 has seen material developments in line with the UK Government’s Industrial Strategy, some highlights are:

  • Major package of industrial sector commitments set out in the Northern Growth Strategy: Includes the City Investment Fund backing a pipeline of priority projects drawn from Local Growth Plans.
  • Increased access to finance: UK Export Finance agrees £11bn lending package with 5 leading UK banks.
  • National Wealth Fund 5-year strategic plan: £27.8bn to be deployed, with a strong focus on crowding in investment into clean-energy.

 

Transition Finance Council (TFC) unveils its first year-end progress report

TFC, established in February 2025, published its first year-end report [5] giving an overview of the progress made by the TFC on the publications launched through the year:

  1. Transition Finance Guidelines (TFG): Voluntary draft guidelines that enable capital providers to identify credible transition finance opportunities at entity-level. These are intended for unlabelled general equity and debt finance to help assess the credibility of a company’s transition planning and implementation and qualify investment as transition finance.
  2. The Finance Playbook: Developed along with the Net Zero Council, the playbook offers practical guidance on integrating robust finance plans within sector transition plans and technology scale-up roadmaps.

Looking ahead:
In its second year, the TFC will shift from framework development to implementation and market engagement, focusing on:

  • International alignment – positioning TFG as a global reference point
  • Industry adoption – supporting companies and investors to apply the guidelines in practice
  • Market development – accelerating transition‑aligned financial instruments and investment
     

UK government publishes national security assessment on global biodiversity loss and ecosystem collapse

The UK’s national security assessment on global ecosystems [6] published in February 2026, highlights how global biodiversity loss and ecosystem collapse could affect UK’s national security. The analysis identifies 6 ecosystems of strategic importance for the UK and explores how their decline could drive cascading global impacts. Some of the findings include:

Key Issue: Cascading global risks

Assessment: Ecosystem degradation could drive geopolitical instability, economic insecurity, conflict, migration, and intensified competition for natural resources.

*AnCR: Moderate


Key Issue:  
Strategic ecosystems

Assessment: Ecosystems supporting global food production and regulating climate, water, and weather systems are critical to UK national security.

*AnCR:  High

 

Key Issue: Food security exposure

Assessment: Without stronger UK food system and supply chain resilience, ecosystem collapse could undermine national food security amid rising global competition.

*AnCR:  Moderate

 

*AnCR: Analytical confidence rating displays the level of confidence in assessing the trends and the likelihood.

Further EU developments

European Commission announces revision of the technical screening criteria under the EU Taxonomy Climate and Environmental Delegated acts

 

Experience from the first years of reporting shows that parts of the technical screening criteria are difficult to apply in practice. Stakeholders have flagged persistent issues, including excessive complexity, poor alignment with updated EU legislation, and unclear or overly detailed requirements - particularly around the “do no significant harm” tests.

 

The consultation focused on targeted simplifications to the EU Taxonomy. The Commission said the changes were aimed at improving usability, encouraging wider uptake, and supporting access to green finance. 

 

What happens next:

  • By 14 April: Stakeholders can submit feedback to the consultation.
  • By summer: The Commission is expected to publish a final revised Delegated Act.
  • Thereafter: The Act will enter a scrutinisation period of up to six months.
  • Earliest application: 2027.

 

Update on the EU Industrial Accelerator Act

The Industrial Accelerator Act (IAA) aims to increase demand for low carbon, European made technologies whilst accelerating permitting and enhancing economic security through the IAA’s introduction of Made in EU” and low carbon requirements for public procurement and public support schemes. Anticipated impacts of the IAA are expected to be:

The IAA aims to accelerate deployment of low carbon EU manufacturing through:

  • Raising manufacturing’s GDP contribution target to 20% by 2035
  • New conditions for investments >€100m in concentrated supply chains
  • Simplified permitting, including single digital systems and tacit approvals
  • Creation of Industrial Acceleration Areas for clean manufacturing clusters

What’s next: The proposal now enters negotiations between the European Parliament and the Council ahead of adoption and entry into force.

EBA launches consultation on discussion paper focusing on the simplification and assessment of the credit risk framework

Following its 2025 efficiency review, the European Banking Authority (EBA) has launched a discussion paper on simplifying Pillar 1 credit risk requirements. The paper explores ways to make the framework simpler and easier to navigate, while preserving risk sensitivity, comparability across banks, and safeguards against regulatory arbitrage.

Key proposals include consolidating overlapping rules, improving structure and presentation, and harmonising definitions to create a more coherent Single Rulebook. The EBA also highlights the integration of environmental and social risks into credit risk modelling, including through stress testing impacts on probability of default (PD) and loss given default (LGD).

Why it matters: While aimed at simplification, the proposals point to more consistent - and potentially more sustainability aware credit assessments, with implications for how banks price and manage risk.

 

 

ECB study finds causal link between climate disasters and the cost of debt 

Climate risk is now being reflected in sovereign borrowing costs, with the strongest effects seen in highly indebted and developing countries. Climate related disasters are already pushing up government bond yields, reinforcing climate exposure as a material sovereign risk factor.

The study differentiates between transition risk and physical risk. Carbon intensive economies face higher funding costs due to decarbonisation pressures and future revenue risks, while acute physical shocks - such as storms and droughts. drive the most persistent increases in yields. Gradual warming, by contrast, shows limited market pricing to date.

 

Fiscal resilience is critical. Countries with low debt tend to see only temporary yield impacts following climate shocks, while highly indebted sovereigns experience larger and longer lasting cost increases, raising debt sustainability concerns.

 

Why it matters for treasury teams: Climate exposure is no longer a long term risk - it is affecting sovereign yields today. For treasurers, this strengthens the link between climate risk, country risk premiums, and funding costs, particularly in emerging and climate vulnerable markets. Physical climate shocks are becoming a measurable input into debt sustainability and risk pricing.

 

For those looking to discuss any of the above further, please reach out to our authors:

Rui Zu, Director, Sustainable Finance Advisory

Usman Zaheer, Associate, Sustainable Finance Advisory

Anika Wadhwa, Analyst, Sustainable Finance Advisory

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