EU ESG wrap-up: afsluiting van 2025 en een blik op 2026

As 2025 has drawn to a close, we turn our gaze to the year ahead and the evolving ESG landscape in the European Union (EU). The past year was characterised by rapid change and uncertainty for EU legislation regarding ESG, with major legislative developments finalised at the end of 2025. In this blog, we briefly discuss recent developments and describe some of the EU legislative developments expected in 2026 and from the European Commission (EC) work programme, and touch upon other developments.

1. What happened as 2025 drew to a close?

In the last month of the year 2025, several important legislative developments emerged from Brussels.

Omnibus I, amending the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), has effectively reached its final state, only awaiting formal adoption by the Council of the European Union after it was adopted earlier in December by the European Parliament. The most significant changes include:

a reduction of the scope of both the CSRD and CSDDD;

a postponement of application dates, although large public interest entities that remain within the revised scope of the CSRD are still required to report over the 2025 and 2026 financial years, and;

several changes to the substantive requirements of both the CSRD and CSDDD.

For a detailed discussion of all amendments introduced by Omnibus I please see our previous blogpost.

Just before the EU Deforestation Regulation (EUDR) would have become applicable on 30 December 2025, the Parliament and Council both approved a set of amendments which went into force only days prior to the original application date. The amendments most importantly:

postpone the application with a year to 30 December 2026;

introduce a simplified regime for the new category of downstream operators and traders, and;

add a provision for mandatory simplification review by the Commission by April 2026.

For a detailed discussion of all amendments please see our blogpost on the amended EUDR.

The EC published its last Omnibus package of the year, the Environmental Omnibus. The package contains proposals aiming to simplify European environmental regulations in order to accelerate the energy transition, among other things. For a detailed discussion of the proposals in the Environmental Omnibus please see our previous blogpost.

2. What is planned and expected in 2026?

The year 2026 will see material ESG developments as well, including the following.

Climate & Energy

The EC’s work programme includes significant initiatives and proposals in the fields of climate and energy, such as:

Energy Omnibus (expected Q2 2026): This proposal will simplify energy product legislation.

Energy Union package for the decade ahead (expected Q3 2026): This package will establish the foundations for CO₂ transportation infrastructure and markets whilst creating a new legal framework for energy efficiency and renewable energies

Climate package for the decade ahead (expected Q3/Q4 2026): This package will contain a revision of national targets and flexibilities in the EU climate policy framework and an update of the EU emissions trading system for maritime, aviation and stationary installations, as well as the relevant market stability reserve.

European integrated framework for climate resilience (expected Q4 2026): This framework aims to establish a more ambitious, comprehensive and coherent EU approach to climate resilience and preparedness, covering individual Member States and the EU as a whole. The framework is intended to promote private and public investment in resilience by removing financial barriers and regulatory fragmentation. A public consultation is online until 23 February 2026.

Energy Union and Climate Action governance update (expected Q4 2026): This update will address, among other matters, phasing-out the subsidisation of fossil fuels and seeks to enhance synergies between national plans and the EU’s overarching objectives

Environmental

Two key environmental initiatives are expected in 2026:

Circular Economy Act (expected Q3 2026): This proposal seeks to stimulate both the demand for and supply of circular products, establishing horizontal standards for design, durability, reparability and recyclability. These measures complement concurrent updates to the rules governing products, market surveillance and standardisation, which are designed to modernise conformity assessment procedures and technical standards.

Ocean Act (expected Q4 2026): Based on a revision of the current Maritime Spatial Planning Directive, this Act is meant to help meet the objectives of the non-legislative Ocean pact, such as restoring degraded coastal marine habitats and boosting a sustainable maritime economy.

Finance

Important Sustainable Finance and financial regulatory developments are expected in 2026:

External reviewers of European Green Bonds must register (by 21 June (Q2) 2026): Currently active external reviewers must notify ESMA of their intention to provide external review services until 21 June 2026. After such date, if an external reviewer of European Green Bonds does not obtain registration or recognition, then any European Green Bonds already issued with external reviews by such external reviewer will not meet all applicable requirements under the EU GB Regulation, as a result of which the issuers of such European Green Bonds will be in violation of the EU Green Bonds Regulation.

ESG ratings subject to supervision (as of 2 July (Q3) 2026): ESG rating providers operating, or issuing, publishing or distributing ESG ratings, in the EU will be subject to strict requirements, mandatory disclosure and supervision as either an EU authorised or non-EU recognised ESG ratings provider by the European Securities and Markets Authorities (ESMA) and must notify ESMA by 2 August 2026 of their desire to apply for authorisation or recognition in the EU (for smaller EU ESG rating providers the deadline is 2 November 2026).

Amendments to the Sustainable Finance Disclosure Regulation (expected 2026): On 20 November 2025, the EC published a proposal to amend SFDR, which included streamlined requirements to simplify disclosures and new labelling for financial products as transition finance, ESG basic and sustainable products, among other changes. The European Parliament and Council are expected to develop their negotiating positions and agree on a final text in 2026.

Revision of the Taxonomy Climate Delegated Act (expected Q1 2026): The revision – relevant to corporate sustainability reporting in annual reports by undertakings subject to CSRD – will become applicable in Q1 2026. Although the revision was already adopted by the Commission on 4 July 2025, it was subject to a six-month scrutiny period by the Parliament and Council. It will now be published in the Official Journal and enter into force. The simplification measures laid down in the revision will apply retroactively as of 1 January 2026 and cover the 2025 financial year. However, undertakings are given the option to apply the measures starting with the 2026 financial year if they find this more convenient.

Reporting and transparency

One major development mayfurther affect reporting obligations:

Revised European Sustainability Reporting Standards (ESRS) (expected Q2 2026): The Commission is expected to adopt the revised ESRS after its review of the draft revision by EFRAG based on a process of consultations. The draft by EFRAG cut a significant number of datapoints from the ESRS and clarified double materiality, however further changes to the final draft are still possible.

Social

Two social policy proposals are expected in Q4:

Digital Fairness Act (expected Q4 2026): This proposal aims to tackle outstanding unfair and deceptive consumer practices such as deceptive or manipulative interface design, misleading marketing by social media influencers, addictive design of digital products and unfair personalisation practices.

Quality Jobs Act (expected Q4 2026): This proposal will ensure that modern employment keeps pace with the modern economy by updating EU rules protecting workers whilst supporting productivity and competitiveness.

We also expect the legislative procedures for several of the various Omnibus packages publicised by the EC last year to continue within the Parliament and the Council, potentially presenting developments within the fields of agriculture, digitalization (including the Batteries Regulation), chemicals and food and feed safety.

3. What other developments should be kept in mind?

Dutch climate litigation

In the Netherlands, we expect a decision in the case of Greenpeace v. The Netherlands, regarding the protection of the population of Bonaire against dangerous climate change. Greenpeace argues that the Dutch government must intensify its efforts to reduce emissions. The Court of First Instance in The Hague is expected to deliver its decision in January 2026.

We may also see the case of Milieudefensie v. Shell come before the Supreme Court of the Netherlands this year, though no official dates have been made public. The case gained international attention in November 2024 when the Court of Appeals in The Hague overturned a court order requiring Shell to comply with specific reduction percentages, whilst maintaining that Shell does have a special obligation in combatting climate change. Any decision by the Supreme Court will have significant legal consequences for the Dutch ESG landscape.

Another case expected to be argued before the Dutch courts in 2026 is Milieudefensie v. ING Bank. The Dutch activist group has brought claims against ING Bank demanding that ING Bank reduces financing to companies in high emission sectors (including steel and air transport) and stops financing companies with new oil or gas projects.

Conclusion

As we step into 2026, the EU ESG landscape remains dynamic and multifaceted. Whilst the final months of 2025 brought material developments through final clarity in relation to Omnibus I and amendments to the EUDR. The year ahead promises a substantial legislative agenda spanning climate, energy, environmental, sustainable finance and social policy domains. Undertakings should prepare for significant legal developments across supervision, reporting obligations, circular economy requirements and climate governance frameworks.