ESG Market Alert UK – November 2025

On 6 November, Hogan Lovells held its fourth annual ESG Game Changers Summit, at which attendees explored how to navigate climate, sustainability, and ESG issues in a time of rising expectations and a rapidly shifting landscape. The Summit also featured a lively discussion between Alastair Campbell and Rory Stewart of ‘The Rest is Politics’, who discussed the importance of constructive disagreement in tackling complex issues such as climate transition, responsible supply chains, and shifting stakeholder expectations. Please see here for further information regarding the GameChangers Summit.

From 6 – 21 November, leading figures from across the globe are gathering in Brazil to discuss the world’s most pressing and fundamental climate crises and possible solutions to work towards at the COP30 climate conference. Please see here for our predictions for the conference and look out for our summary of the key takeaways of COP30 in our December alert.

UK Government launches the Clean Energy Jobs Plan

Who will these changes affect?

• Energy sector employers and supply chain firms, particularly those that are beneficiaries of public grants and government contracts.

How could this affect you?

• The Clean Energy Jobs Plan signals a major government-backed attempt at transitioning the oil and gas workforce to the clean energy sector, which will likely result in legal, operational, and strategic adaptation for those operating in the oil and gas space. If implemented, companies may need to navigate a new regulatory landscape, including new employment laws, compliance obligations, and corporate governance upheavals.

Following record governmental and private-sector investment in clean energy in recent years, the UK Government recently announced its new Clean Energy Jobs Plan (the Plan), which builds upon 2024’s Clean Power 2030 Action Plan and includes initiatives to recruit and train workers to help expand the clean energy sector, with the aim of creating 400,000 additional jobs in sector by 2030.

New initiatives under the Plan include:

• training up the next generation of clean energy workers, whilst also upskilling experienced workers, 90% of whom already possess transferrable skills;
• extending employment law protections, such as the National Minimum Wage, to clean energy sector workers working beyond the territorial seas of the UK; and
• establishing a Fair Work Charter between offshore wind developers and trade unions aimed at increasing wage regulation and improving workplace rights within companies benefitting from public funding.

Under the Plan, the UK and Scottish Governments will invest up to £20 million to support North Sea oil and gas workers transitioning into clean energy roles. These funds will support the expansion of retraining efforts through initiatives such as the Oil and Gas Transition Training Fund.

Alongside opportunities for increased government funding, shifting regulatory environments could generate increased operational burdens for businesses operating in the oil and gas space, including heightened compliance and reporting obligations. Internal policies and practices, such as engagement with trade unions, will likely require updating to address these changes and maintain stakeholder support during any transition period and into the future.

FCA consults on application of pre-existing ESG rules to cryptoassets

Who will these changes affect?

• Any entities operating in the cryptoasset space, or looking to engage with cryptoassets in the future.

How could this affect you?

• The consultation paper sets out how ESG and governance obligations may apply to crypto activities, thus providing an insight into possible future regulation of the industry.

In anticipation of the implementation of proposed statutory provisions which will result in certain cryptoasset activities becoming regulated for the first time, the FCA, one of the entities which will be tasked with overseeing such regulation, has launched a consultation paper (CP25/25), in which it proposes applying the FCA’s existing ESG Sourcebook (the Sourcebook) to cryptoasset firms entering the UK’s authorisation regime. If the Sourcebook is implemented, crypto firms will be required to comply with pre-existing FCA rules regarding anti-greenwashing and restrictions on sustainability labelling when promoting various crypto products to UK consumers.

The consultation, which was launched in mid-September and closed on 12 November 2025, contains several key proposals, including:

• an anti-greenwashing rule aimed at ensuring that sustainability claims made by businesses are fair, clear and not misleading to consumers;
• a prohibition on the use of sustainability labels, unless certain specific asset-management criteria have been met, which crypto firms currently do not meet;
• full application of the FCA’s High-Level Standards, which include obligations to uphold integrity, manage conflict and maintain adequate financial resources whilst operating as a regulated entity; and
• compliance with pre-existing FCA governance and risk frameworks.

At present, the FCA is not proposing crypto-specific sustainability disclosures, citing limited data and the risk of imposing unnecessary financial burdens on crypto firms. Instead, given the varied environmental impacts of different crypto technologies, these firms will be required to follow baseline ESG rules applied to other FSMA-authorised entities, which are largely centered around preventing greenwashing. The FCA is seeking feedback on whether this approach is appropriate for a sector that is still developing.

EU set to scale back key sustainability reporting and due diligence obligations

Who will these changes affect?

• The CSRD and CSDDD (each defined below) apply to companies either established in the EU, or with parent companies or subsidiaries which are incorporated within the EU which meet certain threshold tests.

How could this affect you?

• EU sustainability reporting requirements may no longer apply to many large entities, including, notably, many subsidiaries of non-EU businesses but agreement has not yet been reached.

On 13 November 2025, the European Parliament held its plenary vote on the Omnibus I simplification package. The MEPs adopted a proposal which was put forward by a coalition EPP and right-to-far-right coalition (including ECR and PfE groups). The proposal contained a number of amendments which were not included in the report adopted by the JURI committee on 13 October 2025 and which the Parliament unexpectedly rejected on 22 October 2025. The plenary vote has finalised the negotiation position of the Parliament but the details will not be confirmed until the trilogues have been held and the Commission, Parliament and Council agree. Time is of the essence as companies call on the EU to provide certainty for sustainability reporting and due diligence. Read more here on the background.

The text adopted by the Parliament is different to the negotiating positions of the Commission and Council with significantly higher thresholds for compliance. The Parliament’s negotiating position is as follows (the Commission and the Council’s positions can be found here and here):

• limiting CSRD reporting obligations to entities with at least 1,750 employees and €450 million in annual turnover, which is an increase from the current threshold of 250 employees;
• increasing the CSDDD threshold to apply only to entities with over 5,000 employees and €1.5 billion in turnover;
• removing requirements for transition plans to make business models compatible with the Paris Agreement; and
• removing the civil liability regime introduced by the CSDDD, which will provide more certainty to business which previously faced the possibility of claims brought by private individuals and organisations in respect of breaches of CSDDD reporting obligations.

Trilogue negotiations started on 18 November 2025 with the aim of finalising the amendments by the end of 2025. Sign up to our ESG regulatory tool to keep up to date with the latest developments.

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ESG Counsel

The Hogan Lovells ESG team is here to help, including on all the issues raised in this snapshot. Hogan Lovells is one of the leading ESG firms in the world, delivering uniquely tailored cross-practice and geographic holistic advice as ESG Counsel to clients globally. Our holistic and solutions-driven approach to managing ESG issues draws on the full scope of our global practice and sector capabilities (including our leading global corporate, environmental, governmental relations and regulatory, employment, and dispute resolution teams) to drive sustainable value and maximize positive impact for clients. Please contact us to discuss next steps or for our latest ESG-related materials, including our ESG Academy.

Upcoming events

To hear about upcoming UK events in our Hogan Lovells ESG Gamechangers series, please contact Sarah Laughton to be added to our mailing list.

Authored by John Connell, John Livesey, Rita Hunter, Emily Julier, Scott Prior, Hannah Dingemans, Max Duckworth, Gareth Effiom, Julien Kress, Audrey Tan, and Serkan Yavuz.