This quarter brings further developments in EU and Norwegian sustainability regulation – including the European Commission’s proposal to revise the EU ETS, proposed changes to Norwegian sustainability reporting requirements, new guidance on EU Taxonomy compliance for real estate and the development of an updated BREEAM-NOR manual.
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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 Q3 2026
EU ETS revision: Commission presents proposal to align the system with the 2040 climate target
On 17 July 2026, the European Commission published its long-awaited proposal to review the EU ETS. The proposal includes an adjusted emissions trajectory, changes to the Market Stability Reserve, continued free allocation of allowances under new conditions, the integration of carbon removals and a surrender obligation for municipal waste incineration plants. It is the first part of a package aimed at aligning the EU ETS with the EU's 2040 climate target.
The proposal also strengthens the EU ETS for the aviation and maritime sectors. For aviation, it would include flights departing from the EEA and landing in countries within 5,000 kilometres. For maritime transport, the scope would be extended to smaller vessels with a gross tonnage between 400 and 5,000.
- Read more about the EU ETS for stationary installations
- Read more about the EU ETS for shipping
- Read more about the EU ETS for aviation
Norway: Proposal to implement Omnibus I changes to sustainability reporting
The Ministry of Finance has published its proposal for implementing the Omnibus I Directive changes to Norwegian sustainability reporting rules. Under the proposed framework, only entities and groups with more than 1,000 full-time equivalents and annual net turnover exceeding NOK 5 billion will be subject to CSRD reporting obligations.
Separate, lower thresholds are proposed for Norwegian subsidiaries and branches of non-EEA parent companies.
Norwegian guidance on EU Taxonomy compliance for real estate
On 1 July 2026, EBA, Grønn Byggallianse, Norsk Eiendom and RIF published Norwegian guidance on EU Taxonomy compliance for two activities: (i) construction of new buildings and (ii) acquisition and ownership of existing buildings.
The guidance aims to make it easier for market participants to understand the EU Taxonomy screening criteria for real estate in a Norwegian context and to document compliance. Before the summer, the European Commission proposed amendments to the screening criteria, which are expected to enter into force on 1 January 2027. The organisations behind the guidance have indicated that it will be updated accordingly.
Updated BREEAM.NOR v7 manual under development
An updated BREEAM-NOR v7 manual for new buildings is currently being developed and is expected to be published towards the end of 2026 or in early 2027.
The new version is intended, among other things, to simplify the certification process while ensuring that BREEAM-NOR can still be used to demonstrate compliance with the EU Taxonomy.
