EU Sustainability: State of Play — European Green Deal, Omnibus, and Corporate Sustainability Regulation

Our EU Sustainability: State of Play series focuses on regulatory developments and policy initiatives emerging from Brussels. In this series, we explore EU sustainability frameworks and their intersection with other areas of EU law.

EU sustainability regulations continue to play a key role in shaping the direction of international ESG frameworks. Latham’s European ESG Practice tracks these EU-driven developments closely by drawing on our connections with EU regulators, our presence in Brussels, and our broader European platform.

EU Approach to Sustainability Regulation: The European Green Deal

The European Green Deal (Green Deal) was launched by the European Commission (Commission) as the EU’s flagship strategy to reduce greenhouse gas emissions in the EU by at least 55% by 2030 (compared to 1990 levels) and achieve climate neutrality by 2050For more information on the Green Deal, see the Commission’s webpage. in line with the Paris Agreement. Rather than a single law, the Green Deal is a package of policy initiatives, anchored in multiple cross-sectoral action plans. Key components include:

• The Circular Economy Action Plan, which targets circularity across the life cycle of products by focusing on the design and production required for a circular economy.
• The Green Deal Industrial Plan, alongside the Net-Zero Industry Act and Critical Raw Materials Act, aims to scale up domestic production of strategic clean technologies (such as batteries, wind, solar, and heat pumps), and to secure critical inputs.
• The EU Biodiversity Strategy for 2030, and the more recent Nature Restoration Law, which requires restoration of at least 30% of degraded habitats by 2030, and up to 90% by 2050.

The Green Deal further encompasses a significant number of additional frameworks across topics including energy, energy efficiency, clean technology, transport, packaging, agriculture, and pollution control. The EU’s ambition to transition to a carbon-neutral economy by 2050 also establishes sustainable finance as a central policy pillar.

To this effect, the Green Deal incorporated elements and expanded on the Action Plan for Financing Sustainable Growth (Action Plan), published by the Commission in March 2018. The Action Plan focused on re-orienting capital flows towards a more sustainable economy, mainstreaming sustainability in the context of risk management, and fostering transparency and long-termism. It set out 10 actions to help meet these goals, including several initiatives for key corporate sustainability frameworks. Select actions are shown in the table below.

Table 1: Action Plan Items and Related Frameworks

 

Subsequently, in its Strategy for Financing the Transition to a Sustainable Economy, published in July 2021, the Commission reaffirmed that the directives and regulations set out above would serve as “building blocks” for corporate sustainability regulation in the EU.

Cornerstone Corporate Sustainability Regulations

Under the Action Plan and catalysed by the Green Deal, the EU established a framework of key pillars for corporate sustainability regulation, including the CSRD, the EU Taxonomy, the CSDDD, and the SFDR. This article will discuss the state of play for the first three frameworks.

The CSRD, which entered into force on 5 January 2023, aims to enhance sustainability disclosures by both expanding the requirements of earlier initiatives (including the Non-Financial Reporting Directive) and bringing more companies in scope of ESG reporting rules. Several aspects of the CSRD distinguish it from other mandatory and voluntary corporate sustainability reporting frameworks globally, including the requirement for a double materiality assessment,The double materiality assessment is intended to extend the bounds of materiality past financial materiality only, to include matters in which the undertaking has a material impact on people or the environment, i.e., impact materiality. the requirement for assurance of sustainability information, and the approach to reporting in relation to the value chain.

The CSRD outlines high-level reporting requirements, while the European Sustainability Reporting Standards (ESRS) provide detailed reporting requirements. For a full analysis of the CSRD at the time it entered into force, see this Latham Client Alert.

The EU Taxonomy provides a classification system for sustainable economic activities across six environmental objectives. It aims to provide consistent, technical definitions to direct private capital towards green investments. Companies currently in scope of the CSRD reporting are required to include EU Taxonomy reporting in their reports. Further, the EU Taxonomy and CSRD are closely intertwined with the SFDR, the disclosure regime for financial market participants and financial advisers. For SFDR disclosures, financial market participants rely on EU Taxonomy key performance indicators (KPIs) and CSRD sustainability metrics to report portfolio Taxonomy alignment and principal adverse impact indicators.

Finally, the CSDDD, which was adopted on 13 June 2024, would require in-scope companies to identify, prevent, and mitigate environmental and human rights issues throughout their supply chains (or technically their “chain of activities”). It also mandates the adoption of climate transition plans consistent with the Paris Agreement. Similar to the CSRD, the extraterritorial impacts and extent to which it will affect global value chains are key features. For a summary of the CSDDD at the time it was adopted, see this Latham report.

Together, this unified framework aims to operationalise the Green Deal’s objectives of guiding capital and corporate behaviour towards more sustainable activities and achieving net zero emissions in the EU by 2050.

Clean Industrial Deal: A Competitiveness and Decarbonisation Roadmap

On 25 February 2025, the same day the Omnibus was announced (see below), the Commission launched the Clean Industrial Deal (CID), which is a comprehensive strategy to unify decarbonisation and industrial competitiveness under a single EU growth agenda.

The CID sets out six pillars that form the basis for the strategy in relation to investment relating to energy-intensive industries and the clean-tech sector: (i) ensuring access to affordable energy; (ii) boosting demand for clean products; (iii) financing the clean transition; (iv) circularity and access to materials; (v) acting on a global scale; and (vi) skills and quality jobs. The Commission estimates that the CID will mobilise over €100 billion to support EU clean manufacturing.

On 19 June 2025, the European Parliament (Parliament) adopted a resolution on the CID to urge the Commission to implement it swiftly. On 2 July 2025, the Commission communicated progress on the six pillars in the CID, including adoption of the new Clean Industrial Deal State Aid Framework on 25 June 2025, which provides a framework for Member States to support clean technology.

The EU Omnibus Package

The EU’s Objectives of Competitiveness and Simplification

On 25 February 2025, the Commission also launched its first Omnibus Package on sustainability (the Omnibus). This forms part of the EU’s broader focus on European competitiveness in the recent Competitiveness Compass.The Competitiveness Compass aims to address concerns on productivity while maintaining Europe’s leading role in sustainable innovation and climate neutrality. For more on the Competitiveness Compass, see this Latham blog post. The Omnibus contains a set of legislative proposals designed to streamline certain sustainability frameworks and simplify business in the EU.

The Omnibus proposes ambitious targets, such as reducing reporting burdens by 25%, and by at least 35% for small- and medium-sized enterprises (SMEs). The Commission’s goal is to “square the EU’s ambition towards a sustainable transition with enhancing EU companies’ competitiveness” by eliminating overlapping or disproportionate rules.https://ec.europa.eu/commission/presscorner/detail/bg/qanda_25_615.

To meet these objectives, the Omnibus offers a suite of proposals to amend key EU legislation, including:

• Stop the Clock (CSRD / CSDDD): A directive to postpone (i) CSRD reporting requirements for certain companies, and (ii) the transposition deadline and initial application of the CSDDD (the Stop the Clock Directive)
• Detailed Directive (CSRD / CSDDD): A more detailed proposal containing amendments to the CSRD and CSDDD (the Detailed Directive)
• EU Taxonomy Amendments: Taxonomy proposals to amend the Taxonomy Disclosures Delegated Act (DDA) and the Taxonomy Climate and Environmental Delegated Act

• CBAM Amendments: A proposal for a regulation amending the EU Carbon Border Adjustment Mechanism (CBAM)

While the February 2025 package is the first targeted Omnibus, the Commission has since proposed further measures to achieve simplification of regulatory frameworks. The Commission has also signalled that additional simplification reforms — for instance, in circular economy or environmental regulation — are being considered.

The Omnibus is intended to preserve the objectives of the Green Deal while alleviating regulatory burdens. In this article, we explore the practical effects of these simplification proposals on the CSRD, the EU Taxonomy, and the CSDDD.

The Status of the Omnibus Proposals

Following the Omnibus launch, the European Council (Council) and Parliament both adopted the Stop the Clock Directive without amendment. The Stop the Clock Directive then entered into force in April 2025 via an expedited approval process through the EU regulatory bodies. Member States must transpose the Stop the Clock Directive into national law by 31 December 2025, and a number already have as at the date of this article.For more details on the Stop the Clock Directive, see this Latham article.

The Detailed Directive is progressing through the European legislative process. The Council adopted its position on the Detailed Directive on 23 June 2025, which will form the basis for negotiations with the Parliament.

The Parliament’s Legal Affairs (JURI) Committee held its first exchange of views on the Detailed Directive proposal on 23 April 2025. On 26 May 2025, the first draft JURI report was released, providing insights on potential positions in the Parliament, where discussions on the position are ongoing. A formal vote within the JURI Committee is scheduled for October 2025, followed by a plenary vote later in the month. The final Parliament position is expected in October 2025, after which trilogue negotiations among the institutions will begin.

Omnibus Proposal: CSRD

How Has the CSRD Impacted Sustainability/ESG Reporting?

The CSRD represents a step change in the requirements for corporate sustainability / ESG disclosures across the EU and has broader global impacts. Several aspects associated with the directive, including the double materiality approach, requirement for assurance, and value chain approach, set the CSRD apart as one of the more ambitious frameworks in the global sustainability reporting landscape.

The Timeline for CSRD Reporting

According to the initial CSRD timelines, large public-interest entities that have more than 500 employees have been required to report in 2025 covering the 2024 financial year (Wave 1), with many such entities having already produced their first reports (the precise reporting deadlines vary by Member State).

The Stop the Clock Directive postpones reporting obligations by two years for other companies that were initially in scope (although some of these entities may ultimately be scoped out by the Detailed Directive), deferring those requirements to financial years starting in 2027 or 2028. Notably, the timeline for Wave 1 reporting entities remains unchanged, although these entities are permitted to continue using certain phase‑in reliefs for the 2025 and 2026 reporting years, including extended exemptions from certain ESRS disclosures on certain sustainability topics, such as biodiversity, value chain workers, and affected communities.

See Appendix 1 for a summary of the initial timelines for reporting, and updated timeline as a result of the Stop the Clock Directive.

Proposed Changes to CSRD

Several aspects of the CSRD are expected to be impacted by the Detailed Directive. Key changes include:

Scope

The CSRD applies to certain (i) EU companies and (ii) non-EU global groups, depending on factors such as regulatory status, use of EU capital markets, number of employees, turnover, and balance sheet thresholds.

As part of the EU institutions’ aim to reduce the number of in-scope companies, suggested changes include the proposal to introduce a general employee threshold (set by the Commission at 1,000 employees), updated turnover and balance sheet thresholds, as well the introduction of new exemptions.

Value Chain Cap

A new concept of the “Value Chain Cap” was introduced in the Detailed Directive and is not currently part of the CSRD. This is intended to limit the volume of information requests that CSRD reporting companies may submit to smaller companies within their value chains.

The Value Chain Cap would be tied to the new voluntary sustainability reporting standard. EFRAG developed a draft voluntary standard for SMEs (VSME Standard), which was adopted by the Commission by way of recommendation on 30 July 2025. The VSME Standard is intended to provide a simple, streamlined, and standardised ESG reporting framework for SMEs and reduce administrative burdens entities that report on sustainability matters on a voluntary basis.

As part of the Omnibus, the Commission proposes to adopt a voluntary reporting standard, which will be based on this VSME Standard, for companies with up to 1,000 employees that are not subject to the CSRD. This Value Chain Cap would prevent CSRD reporting companies and financial actors from requesting information for other entities in their value chain above a certain limit, defined in the voluntary standard. While the VSME Standard will serve as the foundation, the content of the future voluntary standard may differ from the current VSME Standard.

The timing of adoption of the voluntary standard depends on the conclusion of negotiations on the Omnibus simplification proposal.

Level of Assurance

The CSRD requires that reported sustainability information is subject to assurance by a qualified independent third party. Under the current version of the CSRD, sustainability reports need to subject to limited assurance, but the Commission is empowered to adopt standards requiring assurance based on a stricter reasonable assurance standard by 2028.For reasonable assurance, the practitioner should reduce assurance engagement risk to an acceptably low level as the basis for a positive form of expression of the practitioner’s conclusion. For limited assurance in comparison, the practitioner collects less evidence than for a reasonable assurance engagement, sufficient for a negative form of expression of the practitioner’s conclusion.

Under the Omnibus proposal, the power to exercise the option to increase to reasonable assurance is removed, with limited assurance maintained. The Commission will issue targeted assurance guidelines by 2026 that clarify the necessary procedures that assurance providers must perform as part of limited assurance.

See Appendix 2 for a detailed comparison of the Commission’s proposal, as well as positions of the Council and the Parliament.

Updated ESRS

In March 2025, the Commission formally instructed EFRAG to revise the ESRS through a delegated act, with the aim of substantially reducing the reporting burden (without weakening the CSRD’s objectives). The significant number of datapoints included in the initial set of ESRS has been an ongoing point of concern for stakeholders, alongside issues relating to the complexity of areas like the double materiality assessment process.

EFRAG submitted its official work plan on 25 April 2025, setting out an accelerated timeline to deliver recommendations by 31 October 2025 (which has since been delayed to 30 November 2025), and launching a public call for engagement.

On 31 July 2025, EFRAG published the draft ESRS for public consultation. It proposed to simplify the double materiality assessment (while maintaining the principle of the assessment), reduce narrative disclosures, improve readability, increase structural clarity, and enhance alignment with international standards — with a more than 50% reduction in mandatory / mandatory-if-material datapoints. See this Latham article for a summary of the proposed amendments to the ESRS subject to public consultation.

EFRAG’s final technical advice is due to be provided to the Commission by 30 November 2025, with the Commission expected to adopt revised standards via a delegated act in mid-2026, in time for financial year 2027 reporting (i.e., for reports published in 2028).

These revisions to the ESRS do not need to be approved by the Parliament and the Council.

Next Steps for the CSRD Under the Omnibus

Looking ahead, the next steps involve finalising the proposed Detailed Directive, which will determine whether the narrowed scope and adjusted thresholds will be formally adopted across the EU. While this legislative process progresses, the already enacted Stop the Clock Directive provides certain companies with immediate relief through deferred reporting timelines.

Despite these simplifications, the CSRD remains a foundational and comprehensive framework for corporate sustainability reporting in the EU. Its integration of double materiality, assurance, and value chain transparency has in many ways set a global benchmark and will likely continue to guide companies, investors, and regulators alike, including in the context of reporting under other mandatory ESG reporting frameworks or in the context of voluntary ESG reporting. As reporting standards evolve and burdens are reduced, the CSRD will likely remain the cornerstone of sustainability disclosure in Europe.

Omnibus Proposal: The EU Taxonomy

What Is the EU Taxonomy?

The EU Taxonomy establishes a classification system defining which economic activities can be classed as environmentally sustainable, based on Green Deal objectives. It enshrines the principle of “do no significant harm” (DNSH) and minimum social safeguards, guiding sustainable investment and corporate disclosure across the EU.

Taxonomy disclosure obligations are nested within the broader CSRD reporting regime. Under the current regime, all companies in scope of the CSRD are required to report certain KPIs (which differ depending on whether the company is a financial institution or not) in accordance with the Taxonomy, intending to ensure that ESG data reported under the CSRD is consistent, comparable, and aligned with sustainable finance goals.

Beyond the CSRD, Taxonomy-aligned KPIs underpin investor decision-making, target setting, and sustainability-linked financing.

Changes to the EU Taxonomy Under the Omnibus

The Omnibus introduced a proposal to make EU Taxonomy reporting voluntary for certain companies that report under the CSRD, by creating an “opt-in” regime. Under the Commission’s proposal, entities in scope of the CSRD with a net turnover below €450 million would only be required to disclose Taxonomy information if they claim their activities are aligned or partially aligned with the EU Taxonomy. In such case, there is a requirement to disclose the EU Taxonomy turnover and CapEx KPIs, and an option to disclose the EU Taxonomy OpEx KPI. The Commission will further be empowered to specify the reporting regime for activities that are only partially Taxonomy-aligned.

Under the Council and JURI report’s proposals, the scope of CSRD and EU Taxonomy reporting would remain aligned. Accordingly, only entities which are in scope within the revised CSRD application criteria would be subject EU Taxonomy reporting. The JURI report proposes to keep the “opt-in” regime and make it available to all entities that fall within the CSRD’s revised scope.

See Appendix 3 for a detailed comparison of the Commission’s proposal, and positions of the Council and the Parliament.

The Omnibus also proposed to amend the Taxonomy Disclosures Delegated Act (DDA) and the Taxonomy Climate and Environmental Delegated Acts.

Key updates from the Commission’s proposals include:

• Materiality Threshold: Exempting activities that account for less than 10% of turnover from detailed reporting requirements
• Simplification of Templates: Streamlining reporting templates to reduce complexity
• Simplification of DNSH Criteria: Particularly concerning pollution and chemical hazards, to enhance usability across sectors

For more information on the aspects of the Omnibus in relation to the EU Taxonomy, see this Latham blog post.

These changes were adopted by the Commission on 4 July 2025 and are under a scrutiny period by the Parliament and the Council, which typically lasts four months and is extendable by an additional two months. As these changes are introduced via delegated acts, the Parliament and the Council can only review and object, rather than amend, the Commission’s text, which will enter into force absent any formal objections.

The amendments would apply from 1 January 2026, covering the 2025 financial year, although entities may choose to defer the application of these rules to the 2026 financial year.

Omnibus Proposal: The CSDDD

The Omnibus proposal introduced several modifications to the CSDDD, aiming to alleviate regulatory burdens while maintaining its core objectives. Similarly to the CSRD, there are notable differences between the Commission’s proposal and the positions of the Council and the Parliament.

Human Rights and Environmental Diligence

In-Scope Entities

Under the current version of the CSDDD, its requirements would apply to EU companies with over 1,000 employees and €450 million in net global turnover, and non-EU companies that have a net turnover in the EU of over €450 million.

The draft JURI report proposes increasing the employee threshold to 3,000, aligning with its proposed thresholds for the CSRD. The Council, however, suggests further increasing the thresholds to companies with 5,000 employees and €1.5 billion in net turnover. The Council notes that these companies “can have the biggest influence on their value chain and are best equipped to absorb the costs and burdens of due diligence processes”.

Scope of Due Diligence Obligations

Under the CSDDD, in-scope companies are required to conduct due diligence across their “chain of activities”. This concept focuses on a company’s operations and upstream activities related to the production of goods or provision of services for a company, with a limited set of downstream activities in scope. These relate to the distribution, transport, and storage of a company’s product.

The “chain of activities” definition has a more limited scope than consideration of the entire “value chain”, which generally includes the full range of activities, resources, and relationships related to the undertaking’s business model and the external environment in which it operates.

In terms of the scope of due diligence obligations under the Omnibus, the Commission suggests narrowing the scope to direct operations and direct business partners (“Tier 1”) and including indirect partners only if there is plausible information of adverse impacts. The Council further proposes to move the focus of due diligence requirements to a “risk-based approach”, targeting areas with likely adverse impacts, and recommends a more limited and not a full value chain mapping exercise.

Value Chain Cap

As discussed above, the concept of the Value Chain Cap is new under the Omnibus proposal. It is also proposed that it would be introduced for the purpose of limiting information requests to smaller business partners by companies in scope of the CSDDD.

Penalties and Civil Liability

The CSDDD requires Member States to establish “effective, proportionate, and dissuasive” penalties — including pecuniary fines — for violations of the relevant provisions. Notably, while Member States have some discretion to set maximum penalties, they may not set those maximum penalties below 5% of a company or group’s net worldwide turnover from the preceding financial year.

The CSDDD also introduces an EU-wide civil liability scheme in relation to failure to adhere to due diligence obligations. Companies may be liable for intentionally or negligently inflicting certain adverse impacts upon individuals or other legal persons, which may authorise certain representative organisations (such as trade unions and NGOs) to enforce their rights.

The Omnibus makes notable adjustments to these aspects. For instance, the Council’s position sets a maximum cap for fines at 5% of a company or group’s net worldwide turnover (rather than a minimum level for the maximum penalties). Further, the Commission’s proposal and the Parliament’s draft JURI report defer to national regimes for civil liability, and would not introduce a mandatory EU-wide scheme.

See Appendix 4 for a more detailed comparison of the Commission’s proposal, and positions of the Council and the Parliament.

Climate Transition Plans

The CSDDD will further require in-scope companies to adopt and implement transition plans for climate change mitigation. These transition plans must aim to ensure, through best efforts, that a company’s business model and strategy align with efforts to limit global warming to 1.5°C in line with the Paris Agreement.

In the context of the Omnibus, the Commission proposes to “align CSDDD’s climate transition plan requirements with the CSRD”, requiring companies to adopt a climate change mitigation plan (with less prescriptive language on implementation). The Council makes several proposals to further limit this obligation and empowers supervisory authorities to advise companies, including making the requirement for a transition plan optional for the first two years. The JURI report, however, proposes to remove the mandatory transition plan requirement altogether.

See Appendix 4 for a more detailed comparison of the Commission’s proposal, and positions of the Council and the Parliament.

Conclusion and Next Steps

The Omnibus Simplification Package introduces significant changes to the CSDDD, aiming to balance the EU’s sustainability objectives with the need to reduce regulatory burdens on businesses.

While these adjustments may alleviate some compliance challenges, certain stakeholders have also raised concerns about the potential dilution of the directive’s effectiveness in promoting corporate accountability for human rights and environmental impacts.

Further Impacts and Next Steps

The Omnibus packages further included a proposal to simplify and strengthen CBAM, a framework designed to prevent carbon leakage by ensuring that imports face comparable carbon costs to goods produced at sites subject to the EU Emissions Trading System (ETS).

The Council and the Parliament reached an agreement on this CBAM simplification proposal on 18 June 2025, retaining essential elements of the Commission’s proposal to simplify CBAM rules, including a broader de minimis exemption for importers. The provisional agreement was endorsed by the Parliament on 10 September 2025, and now awaits formal endorsement by the Council, with formal adoption anticipated before the end of 2025. For more information, see this Latham article.

Further to the Omnibus proposal, the sector has seen a general push to simplify the complex sustainability regulatory landscape in recent years. For example, the EU Deforestation Regulation (EUDR) has been subject to significant calls for adjustment, with a one-year delay to its implementation adopted in October 2024. According to the Commission, this was a response to global partners and stakeholders calling for additional time to prepare for its implementation and enforcement.

Changes to due diligence requirements set under the EU Batteries Regulation are also in progress, aiming to align battery value chain transparency with broader due diligence and reporting.

The Commission proposes to introduce a new “small mid-cap” (SMC) category under the EU Batteries Regulation to broaden exemptions. Under this proposal, economic operators with an annual net turnover under €150 million (and not part of a larger corporate group exceeding that amount) would qualify as SMCs. SMCs would be exempt from the battery due diligence obligations — expanding the current exemption that applies only to SMEs (with under €40 million turnover).

This change is intended to ease the regulatory burden on SMEs, enabling them to grow without facing heavy compliance costs prematurely.

In a further simplification initiative, the Commission recently held a call for evidence (which closed on 10 September 2025) relating to a potential upcoming environmental omnibus proposal. This omnibus would set out measures intended to simplify and streamline environmental legislation concerning the circular economy, industrial emissions, and waste management. More information on the Commission’s simplification agenda and associated omnibus announcements can be found here.

On 21 August 2025, the US and the EU announced that they had agreed on a framework for an Agreement on Reciprocal, Fair and Balanced Trade (EU–US Framework Agreement). Alongside considerations on tariffs, the EU–US Framework Agreement also addresses non-tariff barriers and includes explicit commitments from the EU to review and potentially adjust key sustainability regulations — namely the CSRD, CSDDD, EUDR, and CBAM — to ensure they do not “unduly restrict” transatlantic trade. This political linkage has direct implications for the EU’s ongoing Omnibus sustainability proposals. We will continue to review the status of the negotiating positions over the coming months.

Conclusion: Next Steps in EU Corporate Sustainability

The European Union’s Omnibus package represents a concerted effort to streamline corporate sustainability regulations, aiming to reduce administrative burdens and enhance competitiveness. By narrowing the scope of directives like the CSRD and CSDDD, the EU seeks to focus obligations on the largest companies, thereby alleviating pressure on smaller businesses.

However, this push for simplification has attracted some controversy. Critics argue that the proposed changes may dilute the effectiveness of these regulations, potentially undermining the EU’s sustainability goals. Moreover, the legislative process has faced scrutiny, for instance from the ombudswoman, who has questioned the adequacy of the stakeholder consultations.

For businesses, the evolving regulatory landscape also presents a complex challenge. While the simplification aims to ease compliance, the shifting requirements necessitate continuous adaptation and vigilance.

Further, many EU sustainability-related frameworks that flow from the Green Deal are not impacted by the Omnibus and are of significant relevance for many businesses operating globally with business in the EU.

APPENDICES

Appendix 1

Appendix 2

Appendix 3

Appendix 4

This article was prepared with assistance from Samantha Banfield at Latham & Watkins.

Latham’s European ESG Practice has experience advising on a broad range of EU sustainability and international ESG topics. If you have questions about this article, please contact one of the authors listed below or the Latham lawyer with whom you normally consult.