EU: European Court of Human Rights Addresses Climate-Related Procedural Obligations in Greenpeace Nordic and Others v. Norway
On October 28, 2025, the European Court of Human Rights (the “ECtHR”) delivered its long-awaited judgment in Greenpeace Nordic and Others v. Norway. The ECtHR addressed for the first time the procedural obligation to protect individuals from the serious adverse effects of climate change on their life, health, well-being, and quality of life.
The applicants alleged that Norway’s 2016 award of oil exploration licenses in the Arctic Ocean violated, among other things, Article 8 of the European Convention on Human Rights (the “Convention”), which protects the right to private and family life. In assessing the applicants’ claim, the ECtHR provided important guidance on states’ procedural obligations under the Convention in the climate context. It emphasized that, before approving new petroleum projects, authorities must carry out an adequate, timely, and comprehensive environmental impact assessment (“EIA”) based on the best available science. This includes quantifying anticipated greenhouse gas emissions (including downstream combustion emissions, both domestic and foreign), assessing compatibility with national and international climate commitments, and ensuring meaningful public consultation at a stage when all options remain open.
However, the ECtHR ultimately found no violation of Article 8. In particular, the ECtHR held that Norway, by deferring the EIA to a later stage of the decision-making process, had not exceeded its “margin of appreciation” (namely, states’ space for maneuver in complying with Convention obligations) in balancing economic and environmental considerations.
Link:
Judgment
EU: European Parliament Rejects JURI Committee’s Mandate on Omnibus Amendments
On October 13, 2025, the European Parliament’s Committee on Legal Affairs (the “JURI Committee”) adopted a compromise position on Omnibus amendments to the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD”). The amendments included a proposal to raise the turnover thresholds for companies to be in scope of CSRD and CSDDD to EUR 450 million and EUR 1.5 billion respectively. The JURI Committee also voted to proceed directly to trilogue negotiations with the European Commission and Council of the EU to agree the finalized position, without first seeking a vote from the wider Parliament.
On October 22, the European Parliament voted to reject the position agreed by the JURI Committee. Accordingly, the European Parliament, rather than the JURI Committee, will now vote on the proposed Omnibus amendments at its next plenary session on November 13. This means that Members of the European Parliament and political parties will again be able to submit amendments, potentially reopening parts of the JURI Committee’s agreed position from October 13.
As a result, despite the EU’s aim to finalize the legislation by the end of 2025, any final agreement following trilogue negotiations may be delayed beyond that date.
Link:
Press Release
U.S.: The Fed, FDIC, and OCC Withdraw Interagency Guidance on Climate-Related Financial Risk Management
On October 16, 2025, the Federal Reserve, the Federal Deposit Insurance Corporation (the “FDIC”), and the Office of the Comptroller of the Currency (the “OCC”) announced their joint rescission of the Principles for Climate-Related Financial Risk Management for Large Financial Institutions (the “Principles”). This follows the OCC’s withdrawal in March from its participation in the Principles. The Principles, which were adopted in October 2023, required banks with over $100 billion in assets to integrate climate-related risks into their governance, strategy, and risk management over both short- and long-term horizons. In rolling back the guidance, the regulators stated that the Principles were not “necessary” and expressed concern that maintaining separate climate-specific guidance could “distract from the management of other potential risks.” At the same time, the Federal Register notice expressly stated that the rescission does not “require[] or prohibit[] financial institutions’ consideration of any particular set of risks.”
This represents the latest measures under the second Trump Administration to roll back federal climate oversight in the financial sector. Earlier this year, as we reported here, U.S. banking regulators withdrew from the Network of Central Banks and Supervisors for Greening the Financial System, and the Securities and Exchange Commission abandoned its climate disclosure rules.
Link:
Federal Register Notice
Global: Greenhouse Gas Protocol Launches Two Public Consultations
On October 20, 2025, the Greenhouse Gas Protocol (the “GHG Protocol”), a provider of standards for accounting and reporting greenhouse gas (“GHG”) emissions, launched two public consultations. The first focuses on updating its Scope 2 Guidance regarding inventory accounting; the second seeks feedback on “consequential accounting methods” to estimate avoided emissions in the electricity sector.
The current Scope 2 Guidance, which was developed in 2015, addresses how corporations measure emissions from purchased or acquired electricity, steam, heat, and cooling. Following three years of stakeholder engagement, the GHG Protocol’s proposed updates to the Scope 2 Guidance aim to “improve accounting accuracy, keep GHG reporting methods consistent and align with how electricity is produced and delivered.”
The second consultation relates to reporting “consequential accounting methods,” which estimate the impacts of an organization’s actions to avoid emissions in the electricity sector, including by investing in or procuring clean energy. These impacts are considered “system-wide impacts” because they are outside an organization’s operational boundaries and inventories.
The GHG Protocol is seeking feedback on the draft accounting methods, which can be submitted through this link until December 19, 2025.
Links:
Consultation Release
Consultation Announcement
Consultation Surveys
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