On June 12, 2026, the European Commission (“Commission”) launched its public consultation on guidelines (“Guidelines”) that will significantly shape the implementation of the EU’s Corporate Sustainability Due Diligence Directive (“CSDDD;” more details about the CSDDD available here). The consultation, presented in the form of a detailed questionnaire, is open
Continue Reading European Commission Seeks Public Input on CSDDD Guidelines: What to Watch
Paul Mertenskötter
Paul Mertenskötter advises companies, investors, and governments on regulatory sustainability, international trade, and public policy matters.
Paul has particular experience advising multinational companies on EU sustainability laws, including the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the Taxonomy Regulation, the Forced Labor Regulation, and the Carbon Border Adjustment Mechanism (CBAM). His practice also spans a wide range of climate change issues, including carbon offsets, accounting rules, and related international sustainability reporting frameworks such as the International Sustainability Standards Board (ISSB). Paul further advises clients on their strategic engagement with the rules of the World Trade Organization (WTO), free trade agreements, the Paris Agreement, and general public international law.
Prior to joining the firm, Paul was a Visiting Scholar at the WTO in Geneva, clerked at the International Court of Justice in The Hague, and was a Fellow at the Institute for International Law and Justice at NYU Law School.
European Commission Publishes “ESRS 2.0” for Public Consultation: Draft Closely Follows EFRAG’s Technical Advice with Additional Simplifications for Companies
The European Commission (“Commission”) has launched a four-week feedback period — open until June 3, 2026 — on a draft delegated act to revise the European Sustainability Reporting Standards (“ESRS 2.0”). Ultimately, EU companies in scope of the EU’s Corporate Sustainability Reporting Directive (“CSRD”) will have to draft their annual…
Continue Reading European Commission Publishes “ESRS 2.0” for Public Consultation: Draft Closely Follows EFRAG’s Technical Advice with Additional Simplifications for CompaniesMovement in the UK on Sustainability Reporting
The UK is moving forward with its ambition to become a “world leader for sustainable finance” with two connected projects designed to increase the availability of “high‑quality, decision‑useful” sustainability‑related information for investors and other users of financial statements and sustainability reports. First, the UK government has officially endorsed new voluntary…
Continue Reading Movement in the UK on Sustainability ReportingEU CBAM – Commission Proposes Expansion to Complex Metal Products
In December 2025, the European Commission presented a proposal for a Regulation (“Proposal”) to extend the scope of downstream goods subject to the EU’s Carbon Border Adjustment Mechanism (“CBAM”), and provide flexibility to the Commission to exempt specific products in order address adverse market impacts and…
Continue Reading EU CBAM – Commission Proposes Expansion to Complex Metal ProductsEU CSDDD/CSRD Omnibus Published in Official Journal: Transposition, Delegated Acts, and Guidelines Are Next
On February 26, 2026, the European Union published Directive (EU) 2026/470 on the simplification of the Corporate Sustainability Due Diligence Directive (“CSDDD”) and the Corporate Sustainability Reporting Directive (“CSRD”) in its Official Journal, clearing the final step in the Omnibus I legislative process.
This blog post: (i) summarizes the substance…
Continue Reading EU CSDDD/CSRD Omnibus Published in Official Journal: Transposition, Delegated Acts, and Guidelines Are NextThe CSRD/CSDDD Omnibus Endgame: Key Points for Companies
After months of uncertainty, the outlook for key EU sustainability laws is far clearer.
On November 13, 2025, the European Parliament adopted its negotiating position on the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD”) Omnibus simplification. This follows the European Commission’s Omnibus proposal in…
Continue Reading The CSRD/CSDDD Omnibus Endgame: Key Points for CompaniesTask Force for Corporate Action Transparency Launches New Frameworks for Climate Action Reporting
In the lead-up to COP30 in Brazil, the newly created Task Force for Corporate Action Transparency (TCAT) launched two comprehensive greenhouse gas reporting frameworks designed to fill an important gap in how companies measure, report on, and verify their corporate climate actions. TCAT leadership has indicated that the frameworks will…
Continue Reading Task Force for Corporate Action Transparency Launches New Frameworks for Climate Action ReportingCarbon Measures Coalition Signals Growing Momentum for Ledger-Based Carbon Accounting
On October 20, 2025, a coalition of nineteen leading companies in the energy, finance, and logistics sectors, launched the Carbon Measures Coalition, proposing a significant departure from established carbon accounting frameworks. The Coalition represents a prominent industry-led effort to move away from traditional inventory-based emission calculation methods toward a…
Continue Reading Carbon Measures Coalition Signals Growing Momentum for Ledger-Based Carbon AccountingThe Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for Stakeholders
In late October, the Greenhouse Gas Protocol (“GHG Protocol”) proposed updated Scope 2 guidance for companies quantifying and reporting their greenhouse gas (“GHG”) emissions. If finalized as proposed, the guidance would have significant impacts on how companies plan their renewable energy investments and measure progress toward their climate goals. The…
Continue Reading The Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for StakeholdersState Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program
While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs. Several states, such as…
Continue Reading State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program