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Thommessen Sustainability Update | Q2 2025

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Sustainability regulations continue to evolve, shaping compliance requirements and business strategies across industries. This quarter, the IMO Net-Zero Framework was approved, the Ministry of Finance published a Norwegian translation of EFRAG's voluntary sustainability reporting standard for small and medium-sized enterprises (VSME), The Commission launched a public consultation for the planned 2026 EU ETS regulation revision, and the long-awaited changes to the energy labeling scheme were announced on 1 March 2025. Explore this quarter’s key developments below and stay ahead of regulatory changes with our Sustainability Database.

Stay informed with the latest updates in sustainability

Each quarter, we provide insights into key focus areas such as shipping, responsible business practices, real estate, investment and finance, and overarching regulations. Explore more than 80 updated sustainability regulations and initiatives in our Sustainability Database, or review some key highlights from the past quarter below.

Shipping: The IMO Net-Zero Framework is approved

The IMO Net-Zero Framework was approved in April 2025 and may be formally adopted in October 2025, in which case it will come into force in 2027. The framework aims to achieve net-zero greenhouse gas emissions in shipping by 2050 and is an ambitious initiative by the IMO with many similarities to FuelEU Maritime, but also some key differences. Under the Net-Zero Framework, ships above 5,000 gross tonnage must comply with two functional requirements: reducing their GHG fuel intensity over time and balancing a compliance deficit if they exceed certain annual gas fuel intensity thresholds. Unlike the FuelEU Maritime, there will be different tiers for compliance, in which it will be more expensive to achieve compliance based on how much pollution (CO2 equivalent) the vessel emits. Ships that meet the compliance thresholds will be eligible to receive surplus units, which may be sold to vessels that have failed to meet the base target.

Shipping companies will report to their flag states, and it is expected that the ISM Company will be the responsible party. There are still many details that have not yet been clarified, however, it is clear that the Net-Zero Framework will have far-reaching economic implications and require careful contractual drafting if adopted. In our Sustainability Database we set out what we know about the proposal at this stage.

Sustainability Reporting: VSME Standard Now Available in Norwegian

On 14 May 2025, the Ministry of Finance published a Norwegian translation of EFRAG’s voluntary sustainability reporting standard for small and medium-sized enterprises (VSME). The Ministry recommends that entities choosing to report voluntarily follow this standard, which aims to support consistency and comparability in sustainability disclosures.

Overriding Regulations: Focus on competitiveness on the journey towards Net Zero

The EU ETS is a key policy tool for achieving the EUs climate targets and the Commission has now opened a public consultation where interested parties can have their say regarding the planned revision of the regulations for 2026. We encourage the stakeholders who are covered by or affected by the regulations, as well as those who risk being covered, to provide input before the consultation deadline expires.

In Norway, the Government has proposed to reduce greenhouse gas emissions by at least 70-75% by 2035 as the new climate target, which will be reported under the Paris Agreement. The Proposal will be discussed in Parliament in June. A lot of debate regarding the proposed target concerns the costs and spendings it will require, and whether to specify reducing emissions from Norwegian territory. In addition to this, we are still waiting for the EU Commission to propose their climate target for 2040, proposed to be 90 % by the previous Commission.

Real Estate: Updates to Energy Labelling Scheme and launch of BREEAM-NOR In-Use

The long-awaited changes to the energy labelling scheme were announced on 1 March 2025. Key updates include a revised calculation method and the combination of heating and energy ratings, now represented only by a letter not a color. Due to the changes many buildings are expected to receive a higher energy rating upon renewal. Since these changes take effect on 1 January 2026, it should be considered to delay renewing expired or expiring labels until then.

You should also note that the BREAAM-NOR In-Use manual was launched on 8 April 2025.

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