This quarter brings further developments in EU and Norwegian sustainability regulation – including continued simplification of sustainability reporting, new emissions requirements for offshore service vessels, and important developments in maritime environmental regulation.
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Each quarter, we bring you the Thommessen Sustainability Update, featuring the latest developments in key focus areas, including Shipping, Responsible Business, Real Estate, Investment and Finance, as well as Overriding Regulations. Explore the Sustainability Database for detailed insights into more than 80 sustainability regulations and initiatives, or see this quarter’s key developments below.
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Key developments in Q2 2026
CSRD and ESRS: Omnibus I in force and revised reporting standards under consultation
The Omnibus I Directive entered into force in March 2026, marking a major step in the EU’s simplification agenda for sustainability reporting. The amendments narrow the scope of undertakings subject to sustainability reporting under the CSRD and, by extension, the EU Taxonomy Regulation.
The simplification process has continued in Q2. The European Commission has launched a consultation on revised European Sustainability Reporting Standards (ESRS), with the revised standards expected to apply from financial years beginning on or after 1 January 2027. The overall direction is a narrower reporting scope, simpler disclosure architecture and a stronger focus on information considered material for users of sustainability statements.
SFDR: Review process moves forward
The revision of the Sustainable Finance Disclosure Regulation (SFDR) has advanced further during Q2. The European Parliament’s ECON Rapporteur has proposed stricter requirements for the new product categories, clearer treatment of products that do not fall within a category, and refinements to the role of Taxonomy alignment in the categorisation regime.
The proposal reflects a broader regulatory shift towards clearer sustainability claims and stricter discipline around product categorisation. A final text is expected towards the end of 2026.
Norway: new emissions requirements for offshore service vessels
On 12 May 2026, the Norwegian Government adopted a new regulation on greenhouse gas intensity requirements for offshore service vessels. The regulation introduces a national framework for reducing greenhouse gas emissions from vessels used in offshore petroleum activities, with phased requirements commencing in 2029.
The regulation will apply alongside other developing maritime emissions regimes. If FuelEU Maritime is extended to offshore vessels, and if the IMO Net-Zero Framework is adopted, offshore vessels operating in Norwegian waters may become subject to overlapping regulatory requirements. Operators on the Norwegian continental shelf and shipping companies providing offshore services should assess the implications for their contracts and operations.
HNS Convention to enter into force in November 2027
On 1 June 2026, the IMO announced that the 2010 Protocol to the Hazardous and Noxious Substances Convention (HNS Convention) will enter into force on 29 November 2027, following the fulfilment of all entry-into-force criteria. Norway was the first country to ratify the 2010 Protocol and is now one of twelve Contracting States.
The Convention establishes a two-tier system of liability and compensation for damage caused by hazardous and noxious substances carried by sea. It imposes strict liability on the registered owner, subject to limitation of liability, requires compulsory insurance, and provides for an HNS Fund to cover excess liability up to a specified limit. An estimated 65,000 ships will require HNS certificates of insurance or other financial security. Norwegian shipowners, P&I clubs and receivers of HNS cargo should therefore consider preparations for compliance ahead of the entry-into-force date.
MEPC 84: IMO Net-Zero Framework under debate and North-East Atlantic ECA adopted
At MEPC 84, held from 27 April to 1 May 2026, the IMO continued discussions on the proposed Net-Zero Framework. The framework would establish a global scheme combining mandatory fuel standards with an emissions pricing mechanism. However, the proposal remains subject to political debate, including competing views on the role of an IMO Fund and the balance between mandatory requirements and incentive-based measures. Adoption of the Net-Zero Framework has been deferred to an extraordinary MEPC session in December 2026, and a new proposal from Liberia, Argentina and Panama, favouring incentive-based measures is gaining traction among several delegations.
MEPC 84 also adopted amendments designating the North-East Atlantic as an Emission Control Area (ECA) for sulphur oxides, nitrogen oxides and particulate matter. The amendments are expected to enter into force on 1 September 2027, with the ECA taking effect 12 months later. The new ECA will cover large parts of the North-East Atlantic, including waters stretching from Portugal to Greenland.
New action package for development on grey areas in Norway
As stricter climate requirements move from ambition to reality, a critical question is how environmental targets can be balanced against the need to keep construction costs at a sustainable level. In May 2026, seven real estate, housing and environmental organisations, including WWF Norway, NBBL, Norsk Eiendom and Grønn Byggallianse, launched a joint action package aimed at making it easier, faster and more cost-effective to develop housing and commercial buildings on already developed land, often referred to as "grey areas".
The package is presented as a joint proposal to the Government and Parliament, with measures intended to create stronger economic and regulatory incentives to build on grey areas rather than green areas. Key proposals include reduced document tax for conversion to residential use, clearer municipal authority to grant dispensations from TEK requirements in transformation projects, and simplified change of use from commercial to residential purposes.
SBTi Corporate Net-Zero Standard version 2.0 published
On 11 June 2026, the Science Based Targets initiative (SBTi) published the long-awaited version 2.0 of its Corporate Net-Zero Standard. The updated standard places greater emphasis on implementation, encourages companies to prioritise direct emissions reductions, and clarifies that targets are set on a "best efforts" basis.
The revised standard also introduces a voluntary recognition mechanism for companies taking action on ongoing emissions. This opens the door for the use of high-integrity carbon credits and other climate contributions as a complement to, not a substitute for, companies reducing their own carbon footprint.
Upcoming EU ETS revision expected by July
By July 2026, the EU ETS Directive requires the European Commission to report on several issues, including how to account for negative emissions resulting from greenhouse gases that are removed from the atmosphere and safely and permanently stored.
The Commission’s 2026 work programme also announced a climate package, including a proposal to update the EU ETS expected by July 2026. The revision may become important for the future regulatory treatment of carbon removals and other climate technologies, and we are closely monitoring the process.
UK ETS: expansion to the maritime sector
From 1 July 2026, domestic maritime transport will be included in the UK Emissions Trading Scheme (UK ETS). The expansion will cover ships of 5,000 GT and above on domestic voyages between UK ports, as well as emissions generated in UK ports, including time at berth.
The UK ETS Authority has also proposed expanding the scheme to cover 50% of emissions from international voyages from 2028, while negotiations with the EU on linking the UK ETS and the EU ETS are ongoing. Shipping companies calling at UK ports from 1 July 2026 should assess the implications for their operations and compliance obligations.
