November 2025: EU lowers due diligence and sustainability reporting standards, COP30 updates, big tech and ESG compliance, phasing out PFAs, and more

Key highlights from November 2025 in the sustainability space.

1- European Parliament proposal lowers due diligence and sustainability reporting standards 
On November 13, the European Parliament adopted its negotiation position on the Omnibus Directive amending corporate sustainability reporting and due diligence rules. The proposal raises reporting thresholds to companies with more than 1,750 employees and €450 million in annual turnover, and limits due diligence obligations to firms with over 5,000 employees and €1.5 billion in turnover. 

Among the simplification measures, the revised rules would allow companies to prioritize which risks to assess based on the severity and likelihood of adverse impacts, while also relieving them of the obligation to obtain information directly from business partners across their value chains, permitting reliance on publicly available information. In addition, certain provisions of Directive (EU) 2024/1760 on climate transition would be deferred until 2028 while the Commission develops new due diligence guidelines. 

Negotiations between the European Parliament, the Council, and the European Commission began on 18 November 2025, with the objective of adopting a final text by the end of the year. On the same day, in the spirit of simplification and increasing business competitiveness, expansion and investment, the Parliament also adopted a resolution supporting the BEFIT initiative to harmonise corporate tax rules, citing competitiveness, legal certainty and reduced compliance costs.

The move towards deregulation comes on the heels of trade negotiations with the Trump Administration who has pushed to reduce the burden of the CSRD and CSDDD on U.S. firms. Together, these measures signal a shift towards regulatory simplification and competitiveness, potentially at the cost of sustainability and ESG standards.


2- Federal appeals court enjoins Senate Bill 261 
On November 18, the Ninth Circuit Court of Appeals granted an injunction pending appeal of California's Senate Bill 261, requiring certain companies to disclose climate risks, while staying Senate Bill 253, requiring companies to disclose greenhouse gas emissions.

The plaintiffs, who challenged the legislation on grounds of First Amendment, extraterritoriality and federal preemption, included the U.S. and California Chambers of Commerce. Yet the Ninth Circuit did not limit injunction to members of the plaintiff organisations, effectively suspending enforcement for all covered companies until the appeal is heard in January 2026. 

Meanwhile, delays in the developing regulations for SB 253, particularly those clarifying revenue thresholds and disclosure requirements, have added to regulatory uncertainty for affected companies. This injunction and pending appeals against both statutes risk undermining California's efforts to counterbalance the deregulatory momentum and rollback of climate policies pursued by the Trump administration.

3- COP30 concludes on renewed pledges but no consensus 
From 17 to 22 November, over 60,000 delegates convened in Belém for the COP30 to assess progress on climate mitigation, adaptation and finance. The final decision calls on public and private actors to increase climate finance to at least 1.3 trillion USD annually by 2035, particularly with respect to mitigation and adaptation for developing countries. 

While no consensus was reached on energy transition, several EU countries including Austria, Belgium, Denmark, the Netherlands and Spain signed the Declaration on the Transition Away from Fossil Fuels, and will participate in the first international conference dedicated to fossil fuels in April 2026. Negotiations also focused on contention related to the EU Carbon Border Adjustment Mechanisms and the Deforestation Regulation, signaling potential changes in the regulatory landscape and carbon pricing mechanisms. 

With few binding commitments and no new technical guidance, COP30 confirms a trend of uneven climate transition, led by coalitions of willing states rather than a unified global framework. Fragmented global governance further underscores the relevance of private finance and market-based instruments in driving climate action. 

4- U.S. Attorney Generals warn big tech against ESG compliance 
A coalition of sixteen U.S. state attorneys general has issued formal warnings to Microsoft, Google, and Meta, cautioning against compliance with EU sustainability reporting and due diligence rules on the grounds that adherence could violate domestic legal standards.

The letters accuse the EU of attempting to impose compliance with the Paris Agreement and specifically criticize existing DEI or sustainability initiatives, including Meta’s and Google’s ESG disclosure programs. 

This development underscores the growing compliance dilemma facing multinationals based in the US, which must balance adherence to international sustainability standards against the risk of domestic legal and political backlash, while also managing potential scrutiny from EU regulators in cases of curtailed reporting. 

5- Child rights advocates call for stronger safeguards in African trade integration
Following the release of a  multinational study  on child rights mainstreaming in Africa, the Institute for Human Rights and Development in Africa (IHRDA) urged governments to address child labour and harmful industrial practices as negotiations around the African Continental Free Trade Area (AfCFTA) advance. 

The statement highlights the ongoing lead-poisoning crisis in Kabwe, Zambia, which has affected over 95% of children living and working near former mines, a crisis reflecting not only unsafe environmental practices, but a critical lack of governmental oversight. With the informal sector accounting for over 80% of employment in certain countries, the lack of compliance oversight as well as low entry barriers render youth particularly vulnerable to exploitative practices. Advocates warn that without a robust, enforceable mechanism for child rights at the continental level, deregulated cross-border trade would leave women and children further exposed to exploitation, trafficking and harassment. 

6- Chemical companies move to eliminate PFAS 
BASF, the world's largest chemicals group, has pledged to phase out per- and polyfluoroalkyl substances (PFAS) by 2028, joining a list of major companies renouncing highly persistent "forever chemicals." Citing the need to maintain high safety and environmental standards, the German conglomerate will phase out products formulated with PFAS and substitute with safer alternatives.

This move responds to growing concern among investors concerned about regulatory tightening, compliance obligations and potential litigation exposure, in addition to the impact on ecosystems and public health. According to the ChemSec press release, one third of the world's top 40 chemical companies have indicated they are willing to phase out, reduce or avoid persistent chemicals. 


- Content prepared with the help of Amanda Alden.