Other Notable Developments

Omnibus amendments approved by EU Council: The Council of the European Union has formally approved the simplifications to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), previously agreed by the European Parliament in December 2025 (see prior Debevoise In Depth), with only minor clarifying amendments. The simplifications enter into force on March 18, 2026.

South Korea announces roadmap to adopt ISSB reporting: The South Korean Financial Services Commission announced that sustainability disclosure requirements modelled on the International Sustainability Standards Board (ISSB) standards will be introduced for large KOSPI-listed companies from their 2028 financial years with a three-year grace period for reporting Scope 3 greenhouse gas emissions. The roadmap is subject to public consultation.

Global: UN High Seas Treaty Enters into Force

On January 17, 2026, a landmark treaty governing biological diversity on the high seas—covering over two-thirds of the ocean and roughly half of the Earth’s surface—entered into force.

The treaty, formally titled the “Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas beyond National Jurisdiction” and known colloquially as the “BBNJ Agreement,” was adopted on June 19, 2023. To date, 86 States Parties have ratified the BBNJ Agreement.

The BBNJ Agreement establishes the first comprehensive framework for conservation and sustainable use of marine biodiversity in areas beyond national borders. In particular, the Agreement sets rules to ensure that countries can share the benefits of using marine genetic resources and establishes criteria for area-based management tools, including through the establishment of marine-protected areas (“MPAs”). The Agreement also clarifies the process for conducting environmental impact assessments (“EIAs”) in areas beyond national jurisdiction, with parties required to assess how planned activities in international waters could affect the marine environment.

The BBNJ Agreement seeks to encourage cooperation in ocean management by creating a Clearing-House Mechanism through which states can share relevant information, including in respect of marine genetic resources, MPAs, EIAs, and capacity building.

Links:
UN Press Release

U.S.: SEC Proposes Repeal of ESG Reporting Requirements

On February 18, 2026, the U.S. Securities and Exchange Commission (the “SEC”) proposed amendments to Form N-PORT, the form commonly used by registered investment companies to report portfolio-related information. Among other changes, the SEC proposed modifying Form N-PORT to streamline or remove certain reported information, including removing Names Rule-related reporting items added in 2023 (such as reporting whether the fund has invested at least 80% of the value of its assets in investments consistent with the focus suggested by its name). The “Names Rule” requires in-scope ESG funds whose names suggest an ESG investment focus to include such reporting information in their Form N-PORT filings.

Separately, the SEC extended the compliance dates for the Names Rule-related Form N-PORT reporting requirements while the Commission considers comments on the proposal.

Links:
SEC Press Release

EU: European Parliament Approves 2040 Emissions Reduction Target of 90%

On February 10, 2026, the European Parliament approved amendments to the European Climate Law, which had established the European Union’s objective of climate neutrality by 2050, as well as a target of reducing greenhouse gas (“GHG”) emissions by at least 55% by 2030 (for more details, see our previous ESG Update here). The amendments establish a new binding 2040 target to reduce GHG emissions by 90% compared to 1990 levels.

The European Commission will assess progress toward the 2040 target every two years and may propose amendments to the European Climate Law, which could involve modifying the 2040 target or taking additional measures to strengthen the supporting framework.

The revised European Climate Law introduces flexibility in how the 2040 emissions reduction target can be met: (i) from 2036, up to five percentage points of net emissions reductions can come from high-quality international carbon credits from partner countries, subject to safeguards; and (ii) domestic permanent carbon removals can also be used to compensate for hard-to-abate emissions under the EU Emissions Trading System.

The launch of ETS2, the emissions trading system for buildings and road transport, will be postponed from 2027 to 2028.

To enter into force, the text must be formally approved by the European Council, following which the amendments will take effect 20 days after publication in the Official Journal of the EU.

Link:

Global: Net Zero Asset Managers Initiative Announces Relaunch

On February 25, 2026, the Net Zero Asset Managers (“NZAM”) initiative announced it was relaunching, ending a one-year hiatus that followed its suspension in January 2025. 

As part of its relaunch, NZAM has unveiled a new Commitment Statement, which signatories must adhere to when setting voluntary commitments and making public disclosures. The Statement continues to support the ultimate global target of net zero GHG emissions, as well as pursuing efforts to limit global temperature increases to 1.5°C above pre-industrial levels. However, the Statement no longer refers to achieving net zero GHG emissions by 2050, nor does it require asset managers to set interim GHG emissions reduction targets for 2030 with respect to certain assets. Currently, over 250 asset managers have signed the new Commitment Statement. 

Link:
NZAM press release

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