This quarter brings significant developments across EU and Norwegian sustainability regulation – including the Commission’s proposal for a revised SFDR, the Parliament’s mandate to narrow the CSRD scope, Norway’s proposal to regulate emissions from offshore vessels, newly adopted CBAM simplifications, the postponement of the IMO Net-Zero Framework, and new rules for building energy labelling.
Keep up with the latest in sustainability regulation
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 on over 80 sustainability regulations and initiatives, or explore this quarter's key developments below.
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Commission unveils proposal for a revised SFDR
The European Commission has published its long-awaited proposal for a revised Sustainable Finance Disclosure Regulation (SFDR). Key proposed changes include the introduction of three distinct categories of sustainability-related financial products ("Sustainable", "Transition" and "ESG basics") and removal of disclosure requirements at the "entity-level".
Parliament adopts mandate for CSRD scope reduction negotiations
The European Parliament has adopted its negotiation mandate for the trilogue on the European Commission's "Omnibus I"-proposal from February concerning, among other things, reducing the scope of entities subject to sustainability reporting requirements introduced by the Corporate Sustainability Reporting Directive (CSRD).
The Parliament proposes an employee-threshold of 1,750 and an annual net turnover-threshold of EUR 450 million, reducing the scope of reporting entities even further than what would follow from the Commission's proposed employee-threshold of 1,000.
Proposal for a national regulation on emissions from offshore vessels on the Norwegian Continental Shelf
The Norwegian Environment Agency (NEA) has put forward a novel national proposal that would specifically target offshore operators’ combined fleet emissions. The proposal entails many similarities to the FuelEU Maritime and the IMO Net‑Zero regulations, however, there are also significant differences concerning e.g., the responsible entity and permissible fuels.
The proposal has been subject to an industry consultation which closed on 3 October 2025, and NEA may now redraft and submit the proposal to the Norwegian Parliament for debate.
CBAM simplification adopted and applicable
CBAM was formally simplified by amendments on 20 October 2025. The amendments introduce a new de minimis mass threshold that exempts up to 50 tonnes of CBAM goods per importer per year, alongside streamlined rules for authorisation, calculation and timing from 2026. This significantly reduces administrative burden while keeping more than 99% of emissions within scope.
In Norway, the Government has proposed a CBAM Act to implement Regulation (EU) 2023/956, which also entails changes to Norwegian customs legislation. The bill was published for consultation in October 2025, with a deadline of 2 January 2026. The Government aims to implement the CBAM regime from 2027, with rules on authorised CBAM declarant status expected to enter into force earlier to allow entities to prepare.
IMO Net-Zero Framework postponed
The IMO Net-Zero Framework was set to be adopted in the extraordinary session of the IMO's Marine
Environment Protection Committee in October, however, surprisingly, the parties failed to agree on a path to adoption and instead opted to postpone the vote by a year. The postponement entails that the IMO's ambition for a world-wide GHG emissions reduction regulation has an uncertain future, and that the planned timelines for the phase-in will be altered.
Revised Energy Labelling Scheme takes effect
From 1 January 2026, a revised calculation method for building energy labels will apply. Many buildings are expected to achieve a more favourable rating under the new calculation method. If you are planning to sell or refinance, consider renewing your label under the revised scheme once it takes effect, even if your current label has not yet expired. The revised method will also be used to determine whether a building qualifies among the top 15% most energy‑efficient buildings nationally under the EU Taxonomy. The criteria for the top‑15% threshold were defined earlier this year.
