Sustainability is rising rapidly up the pensions agenda because of a mix of changing law, regulatory guidance, and growing demand from pension scheme members and other stakeholders.

A regular briefing for the alternative asset management industry. 

As the new year begins and the financial services regulatory landscape across the UK and European Union continues to evolve, Travers Smith is pleased to present our 2026 Regulatory Roadmap. 

As reported in our previous briefing, the Sustainability Omnibus finally reached its destination last week, when the European institutions agreed on changes to the Corporate Sustainability Reporting Directive ("CSRD") and the Corporate Sustainability Due Diligence Directive ("CSDDD"). The text was subsequently approved by the Council's Coreper committee on 10 December, and on 16 December, the Parliament approved the text in its plenary session. Some sources are noting that final publication of the text will be in March 2026, with entry into force twenty days later, but importantly, no further substantive changes are expected. 

The UK Government is consulting on a proposed change to the inflation indexation measure underpinning two of its cornerstone renewable energy relief schemes: the Renewables Obligation ("RO") and the Feed-in Tariff ("FiT"). The Government ultimately hopes that changing these from the Retail Price Index ("RPI") to the Consumer Prices Index ("CPI") will deliver savings for consumers, at a time when the purported cost of Net Zero has become a heavily politicised issue. However, these changes could have a significant commercial impact on existing projects (and their financing) and also dampen investor confidence in the UK's historically stable renewable energy regulatory regime, at the exact moment that the Government needs to crowd in private capital to deliver its Clean Power by 2030 goal.

The European Parliament, the Council and the Commission concluded negotiations late on 8 December on the Sustainability Omnibus, the highly politicised proposal to amend the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. Though the agreed text is not available at the time of writing, the Council and the Parliament issued press releases with key details.

In our first COP30 article we highlighted the difficult challenges facing the conference, amidst a backdrop of a general sense of retreat and pessimism in the international climate community. With an energetic presidency and aims of focusing on climate implementation and nature protection, COP30 was seen by many to be pivotal.