Climate and Energy: EU Policy and Regulation Update for 16 September 2026
September 16, 2026
As policy and regulatory landscapes evolve, this publication will provide insights to navigating emerging risks and opportunities in the energy transition. Read previous issues here.
- ESMA updates transitional notification and small-provider registration lists under the ESG Ratings Regulation
- ECON adopts its position on the proposed SFDR 2.0
- ESMA reports continued growth in EU ESG bond markets and mixed ESG fund flows
- EFRAG seeks input on the costs and benefits of ESRS-40a for certain non-EU undertakings
- Euronext publishes its 2026 Sustainability Reporting Guide
- AMF publishes guidance on clearer KIDs, including the presentation of ESG information
- French authorities highlight areas for improvement in corporate climate-adaptation reporting
- IVASS published a report on risks from natural catastrophes and insurance coverage
European Union/International
9/10 September 2026 [EU] – ESMA updates transitional notification and small-provider registration lists under the ESG Ratings Regulation
The European Securities and Markets Authority (ESMA) updated two public lists under Regulation (EU) 2024/3005 on the transparency and integrity of ESG rating activities (EU) 2024/3005 (ESG Ratings Regulation):
- Providers that have notified ESMA under Article 51: the updated list [available here] identifies ESG rating providers that have notified ESMA under the transitional arrangements in the ESG Ratings Regulation. As at 9 September 2026, the list included 109 providers. Existing providers other than small ESG rating providers were required to notify ESMA by 2 August 2026 and must submit an application for authorization or recognition by 2 November 2026 in order to continue operating in the EU while ESMA considers their application.
- Small ESG rating providers registered under Article 5: the updated list [available here] identifies small ESG rating providers established in the EU that ESMA has registered under the temporary regime provided for in Article 5 of the ESG Ratings Regulation. As at 10 September 2026, the list included 34 providers. The regime allows qualifying small providers to operate under a more proportionate set of requirements for up to three years from the date of their registration, or until they cease to qualify as small ESG rating providers, whichever occurs first. They must then apply for full authorization within six months.
28 July 2026 [EU] – RAG publishes materials on the revised ESRS and VSME
The European Financial Reporting Advisory Group (EFRAG) released interactive versions of the revised European Sustainability Reporting Standards (ESRS) and Voluntary reporting standard for smaller companies (VSME), as adopted by the European Commission on 3 July 2026 [see further here, in our previous edition].
The new interactive document set [available here] includes all revised topical ESRS standards and the VSME, an interactive glossary, and list of defined terms, along with comparison tools to allow users to view the evolution of the final text from the 2023 ESRS and the 2025 simplified ESRS initially published by EFRAG.
This release is intended to support preparers and other stakeholders in understanding, navigating, and applying the revised ESRS and VSME more effectively.
The ESRS and the VSME will become legally effective only upon their publication in the Official Journal of the European Union, following the expiry of the two-month scrutiny period (which may be extended once) that began upon their transmission to the European Parliament and the Council of the EU in July 2026.
10 September 2026 [EU] – ECON adopts its position on the proposed SFDR 2.0
The European Parliament’s Committee on Economic and Monetary Affairs (ECON) adopted its draft report on the European Commission’s proposal to reform the Sustainable Finance Disclosure Regulation (SFDR 2.0) and approved the opening of interinstitutional negotiations [see the European Parliament’s press release here]. The Commission’s proposal is available here, and our previous edition summarizing the proposed changes is available here.
ECON’s decision to enter into interinstitutional negotiations is expected to be announced at the start of the European Parliament’s first October plenary session. Once Parliament’s negotiating mandate has been confirmed, trilogue negotiations can begin with the Council and the European Commission. The Council adopted its own negotiating mandate on 24 June 2026 [see further here, in our previous edition]. Any provisional agreement reached during the trilogue negotiations will then need to be formally approved by both the European Parliament and the Council before the amending regulation can be published in the Official Journal of the European Union and enter into force.
10 September 2026 [EU] – ESMA reports continued growth in EU ESG bond markets and mixed ESG fund flows
ESMA published its second Trends, Risks and Vulnerabilities report of 2026 [available here]. In its sustainable-finance section, ESMA reports that the outstanding volume of EU ESG-labelled bonds exceeded €2.8 trillion. Green-bond issuance amounted to approximately €181 billion during the first half of 2026, while sustainability-bond issuance reached €24 billion, representing a 20% year-on-year increase. Bonds issued under the European Green Bond Standard (EuGBs) accounted for approximately 10% of overall EU ESG-bond issuance.
ESMA also notes that, since 2021, more than 70% of EU green-bond issuances have identified at least one use of proceeds linked to renewable-energy projects. However, because each issuance may specify several uses of proceeds this percentage should not be read as the proportion of total proceeds allocated to renewable-energy projects.
ESMA further reports mixed flows across EU ESG funds during the first half of 2026. Funds disclosing under Article 8 of the SFDR attracted approximately €145 billion in net inflows, equivalent to 2.3% of assets under management, while funds disclosing under Article 9 recorded net outflows of approximately €0.3 billion, equivalent to 0.3% of assets under management. Thematic strategies focused on the low-carbon transition and renewable energy nevertheless attracted positive inflows. Dedicated renewable-energy UCITS attracted approximately €2.8 billion, while transition-focused UCITS also recorded net inflows.
11 September 2026 [EU] – EFRAG seeks input on the costs and benefits of ESRS-40a for certain non-EU undertakings
The European Financial Reporting Advisory Group (EFRAG) launched an online survey to inform its cost-benefit analysis of the Exposure Draft European Sustainability Reporting Standards for Certain Non-EU Undertakings (ESRS-40a) [see EFRAG’s press release here and the survey here]. The survey is directed at non-EU undertakings expected to fall within the scope of the reporting requirements under Article 40a of the Accounting Directive (Directive 2013/34/EU, as amended) and seeks information on the anticipated costs and benefits of implementing the proposed requirements. Responses are due by 11 October 2026 at 23:59 CEST.
The survey is being conducted in parallel with EFRAG’s broader public consultation on the ESRS-40a Exposure Draft, which is open to interested stakeholders both within and outside the EU until 31 October 2026 [see further here, in our previous edition].
14 September 2026 [EU] – Euronext publishes its 2026 Sustainability Reporting Guide
Euronext published its Sustainability Reporting Guide 2026 [available here] as part of Euronext Sustainability Week 2026. Intended for private companies, listed SMEs and large issuers, the guide is designed to help businesses navigate developments in the European sustainability-reporting landscape, integrate ESG considerations into their strategy, governance and capital-allocation decisions, and communicate their approach to investors. Euronext presents the guide as relevant both to companies preparing for an initial public offering or bond issuance and to those responding more generally to investor demand for sustainability information.
The guide addresses, among other topics, the ongoing simplification of the Corporate Sustainability Reporting Directive (CSRD), the European Sustainability Reporting Standards (ESRS) and EU Taxonomy framework, the proposed reform of the SFDR, the ESG Ratings Regulation, the voluntary sustainability-reporting standard for SMEs (VSME Standard), the European Single Access Point, climate-transition plans, and biodiversity reporting. It also provides practical recommendations concerning internal preparation and ESG governance, materiality assessments, the selection of relevant indicators, ESG data management, reporting roadmaps and external communications. The guide includes case studies on Enel’s double-materiality assessment, AXA Investment Managers’ use of ESG data, and Veolia’s climate-transition plan, including Moody’s net-zero assessment of that plan.
France
8 September 2026 [France] – AMF publishes guidance on clearer KIDs, including the presentation of ESG information
The French Financial Markets Authority (AMF) published a practical guide intended to improve the readability of key information documents (KIDs) provided to retail investors [available here]. The guide draws on a qualitative study conducted in 2025, in which 50 investors reviewed several equity-fund KIDs. Participants generally found the documents unattractive in presentation, complex in substance and insufficiently accessible to novice investors. The main difficulties concerned the “What is this product?” section, which describes the product’s objectives and investment strategy. The AMF recommends improving the presentation of KIDs, structuring that section more clearly and applying plain-language principles.
Although the guide is not specific to sustainable-investment products, it includes a worked example addressing the presentation of ESG information. In that example, wording referring to the systematic integration of environmental, social and governance criteria and to Article 8 of the SFDR is identified as difficult to understand and replaced with a simpler description of the fund’s objectives. The example therefore suggests that manufacturers of products incorporating ESG characteristics should describe the relevant ESG-related objective or approach in straightforward terms, rather than relying principally on technical terminology or references to regulatory classifications.
11 September 2026 [France] – French authorities highlight areas for improvement in corporate climate-adaptation reporting
French Treasury, in coordination with the Commissariat général au développement durable, published its first assessment of public corporate reporting on climate-change adaptation [see here]. The assessment was undertaken pursuant to action 2 of measure 40 of France’s third National Climate Change Adaptation Plan (Plan national d’adaptation au changement climatique, PNACC-3), published in 2025.
The assessment covers the 2025 or 2024/2025 sustainability reports of 42 companies operating across a range of sectors, including several considered particularly exposed to the effects of climate change. It considers the extent to which the reports address relevant ESRS requirements under the CSRD and evaluates the reported development of companies’ adaptation approaches, using elements of ADEME’s ACT Adaptation methodology.
The main findings include:
- The companies received an average score of 48.5 out of 100 for the quality of their reporting and 36 out of 100 for the maturity of their reported adaptation approaches. Around one-quarter of the sample performed relatively strongly on both measures, while most companies scored near the overall average.
- Disclosures concerning the identification of physical climate risks and the adoption of adaptation policies were generally more developed than disclosures concerning resilience assessments, future actions, targets and resources. Only 2 companies provided a complete analysis of the resilience of their business model and strategy, 13 reported planned adaptation actions, and four reported precise adaptation targets supported by indicators.
- Only one company fully specified the financial resources allocated to adaptation, while another did so partially.
- 23 of the 42 reports considered climate-related risks or adaptation issues affecting the company’s value chain.
The report identifies several priorities for improving future disclosures. These include linking identified climate risks and adaptation needs to concrete actions and financial resources; setting measurable, time-bound targets; extending the analysis beyond companies’ own operations to their value chains; and providing more information on the anticipated financial effects of physical climate risks.
Italy
31 August 2026 [Italy] – IVASS publishes a report on risks from natural catastrophes and insurance coverage
On 31 August 2026, the Italian Insurance Supervisory Authority (IVASS) published its 2026 report on natural catastrophe and sustainability risks in Italy, presenting the main findings of its fourth annual survey since 2022, based on data as at year-end 2024 [available here, in Italian].
The survey covers insurers and reinsurers headquartered in Italy and branches of non-EEA insurers authorised to operate in Italy. It combines quantitative data on underwriting and investments with a qualitative assessment of governance, risk management, business and investment strategies, and physical and transition risk impacts.
In particular, the report examines how insurers integrate ESG factors into strategic decision-making, the effects of physical risks on underwriting and technical profitability, and exposure to transition risks within investment portfolios. It highlights significant economic losses from catastrophic and environmental risks that remain uninsured in Italy, identifying the reduction of the insurance protection gap as a continuing priority.
The findings included in this edition of the Report do not yet capture the effects of the new rules (including the introduction in Italy of mandatory insurance covering damage caused by natural disasters and catastrophic events for companies with a registered office or permanent establishment in Italy) whose entry into force has been phased in between 2025 and 2026 depending on company size and sector of activity.