COP27 regulatory briefing: stock-take of policy developments

At a glance

• The 27th session of the Conference of the Parties to the UN Framework Convention on Climate Change (COP27) was held in Sharm el-Sheikh, Egypt in November 2022.
• Alongside the main Conference agenda, various regulators and other standard-setting bodies used COP27 as an opportunity to publish policy updates. We identified six themes from the updates: transition plans; product labels and disclosures; corporate reporting and disclosures; climate risk management; nature and pollution; and energy and food. For each theme, the slide pack attached summarises the main developments, our takeaways and further reading.

COP27

The 27th session of the Conference of the Parties to the UN Framework Convention on Climate Change (COP27) was held in Sharm el-Sheikh, Egypt in November 2022. An important area of focus for this year’s Conference was on “loss and damage” – new funding arrangements and a dedicated fund to provide financial support for developing countries that are particularly vulnerable to the adverse effects of climate change. A “transitional committee” will be established to make recommendations by COP28 next year on how to operationalise this.

There were though also missed opportunities in critical areas elsewhere, including in the outcome agreement of the Conference, which failed to call for a phase down of all fossil fuels. This occurred despite the need for rapid progress to be made to reduce greenhouse gas emissions. Underpinning the sense of urgency for action were new findings that countries’ current climate commitments, if fully implemented, would result in emission reductions by 2030 that fall drastically short of the decrease needed to limit global warming to 1.5 degrees.

For further reflections on the outcomes of COP27, please see ‘What you need to know about COP27: Three takeaways from the latest climate talks’.

Key policy updates

Alongside the main Conference agenda, various regulators and other standard-setting bodies used COP27 as an opportunity to publish policy updates. Despite the mixed success of COP27 itself, regulators and standard setters seem to be continuing apace with their plans.  The challenge may come if or when those regulations and standards have to be implemented into national and regional legislation, at which point policies may encounter delays or amendments.  But where things can be done by regulators alone, we expect them to continue to move at full steam.

The presentation attached takes stock of some of the key regulatory and policy developments at the international level and in Europe in the run up to and during the Conference (between 24 October and 18 November 2022). We identified six themes from the updates. For each theme we summarise the main developments, our takeaways and further reading.

• Transition plans: The development and disclosure of transition plans will be a priority for firms in 2023, with newly-published guidance on plan development and disclosure requirements by the UN High-Level Expert Group, the Glasgow Financial Alliance for Net Zero and the UK’s Transition Plan Taskforce.
• Product labels and disclosures: New proposals aimed at tackling greenwashing in investment management are part of rapidly-increasing regulatory action on greenwashing.
• Corporate reporting and disclosures: Reporting requirements are set to increase. The EU Corporate Sustainability Reporting Directive (CSRD) will shortly enter into force, following its agreement in the European Parliament plenary. A key challenge for large corporates will be navigating the complex disclosure landscape across jurisdictions.
• Climate risk management: Financial services firms are expected to continue to develop their capabilities in climate risk management and scenario analysis.
• Nature and pollution: Increasing attention is being paid to nature risk and pollution, including significant changes provisionally ahead for the automotive industry. An updated Task Force for Nature-related Financial Disclosures (TNFD) framework for managing and disclosing nature risks is available for organisations to pilot.
• Energy and food: There were also a number of measures to support energy and food security and decarbonisation in the EU.

See the presentation for further information.

As the regulatory policy landscape for climate and sustainability becomes increasingly complex, as well as tracking changes, it is critical for firms to also understand the relationships and inter-dependencies between requirements.