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Paul Mertenskötter

Paul Mertenskötter advises companies, investors, and governments on regulatory environmental, social, and governance (ESG), 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.

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 Companies

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 Reporting

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 Accounting

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 Stakeholders

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

On June 23, 2025 the Council of the EU, which represents the 27 EU Member States, agreed on its negotiating mandate for the Corporate Sustainability Reporting Directive (“CSRD”) and Corporate Sustainability Due Diligence Directive (“CSDDD”) omnibus simplification.

This follows the European Commission’s omnibus proposal from February and is the next

Continue Reading EU Member States Agree on CSRD/CSDDD Omnibus Negotiating Mandate

After its 12-month deferral, the EU’s Deforestation Regulation (“EUDR”) is set to apply from December 30, 2025.  Many companies are therefore refocusing EUDR compliance efforts. This blog provides an update on the rules and guidance and key, practical takeaways for companies.

The European Commission (“Commission”) recently provided new and updated

Continue Reading EUDR Back on the Horizon: Preparing for December 2025 Compliance

On May 28, the Biden-Harris Administration issued the Voluntary Carbon Markets Joint Policy Statement and Principles (Policy Statement).  You can find Covington’s analysis of the Policy Statement here.  Jointly announced by the U.S. Secretaries of Treasury, Agriculture, and Energy, and senior White House climate officials, the Policy Statement describes a three-pronged approach to responsible carbon market development and participation: (1) credit or supply integrity, including protections regarding climate and environmental justice; (2) demand integrity, to ensure the credible use of credits; and (3) market-level integrity, including facilitating efficient market participation and lowering transaction costs.  The Policy Statement builds on other recent federal actions, including the Commodities Futures Trading Commission’s 2023 proposed guidance for voluntary carbon credit derivatives and the Securities and Exchange Commission’s final climate risk disclosure rule, which requires certain disclosures related to carbon offset purchases, in the Administration’s attention to and elevation of the voluntary carbon market as an important element in the nation’s climate policy. 

In this post, we dive deeper into the voluntary carbon market landscape, implications for business, and additional recent developments. Continue Reading Engaging in Voluntary Carbon Markets: Overview of Key Developments, Risks, and Opportunities

In the early hours of December 14, 2023, the Council of the EU (“Council”) and the European Parliament (“Parliament”) reached a provisional political agreement on the Corporate Sustainability Due Diligence Directive (“CSDDD”). Described as a “historic breakthrough” by Lara Wolters, who has led this file for the Parliament, the CSDDD will require many companies in the EU and beyond to conduct environmental and human rights due diligence on their global operations and value chain, and oblige them to adopt a transition plan for climate change mitigation.

Given the CSDDD’s relevance for companies’ ongoing compliance planning on environmental and human rights matters, this blog aims to advise clients on the basic elements of the CSDDD agreement based on press releases from the Council, Parliament, and the European Commission (“Commission”), even if much uncertainty remains. Although a political agreement has been reached, the text of the agreement is not publicly available and a number of details of the legal text will need to be finalized in follow-up technical meetings. Covington will publish a more detailed alert on “how to prepare” for the CSDDD once the full text is available (likely in early 2024).Continue Reading Provisional Agreement on the EU’s Corporate Sustainability Due Diligence Directive (CSDDD): Key Elements of the Deal

What You Need to Know.

  • After two days of intense negotiations, world leaders adopted a draft decision that sets out international climate priorities in response to the findings of the first Global Stocktake under the Paris Agreement.  The decision covers several thematic areas, including mitigation of greenhouse gas emissions, adaptation and resilience in the face of climate change, financing and means of implementation and support for climate projects, and loss and damage funding for climate-vulnerable nations.  The text of the draft decision can be found on the UNFCCC’s website here.

Continue Reading COP28 Final Negotiations Recap: A Global Agreement to Transition Away from Fossil Fuels