Linklaters

On 21 September 2026, the European Commission adopted a Delegated Regulation establishing a mandatory EU-wide sustainability rating scheme and electronic label for data centres (see Commission press release). The Delegated Regulation supplements the Energy Efficiency Directive (Directive (EU) 2023/1791) and amends Delegated Regulation (EU) 2024/1364.

On 14 October 2026, the Commission has adopted a Proposalto postpone by one year certain requirements under the EU Methane Regulation. The proposed amendments relate to monitoring, reporting and verification requirements for importers of natural gas, oil and coal, as well as methane-intensity reporting requirements for both importers and EU producers. Why the delay is being proposed The Commission's press release notes that Europe is preparing for a challenging winter with high energy prices.

The Australian High Court's decision in MACH Energy v DAMSHEG has attracted significant attention in the media and across the resources and energy sectors, with questions emerging about the role of scope 3 emissions in project approvals. In their latest client briefing, the Allens team (our Alliance partners) separate fact from commentary, unpack what the Court actually decided and explore the implications for project proponents and future environmental assessments.

In the latest stage on the journey of SFDR 2.0 through the EU legislative process, the European Parliament's ECON Committee has adopted its report on the review of the Sustainable Finance Disclosure Regulation and approved the mandate to open trilogue negotiations with the Council. The Parliament has now announced its negotiating mandate, with the first trilogue meeting between the Parliament, Council and Commission expected to take place shortly in October.

In the latest stage on the journey of SFDR 2.0 through the EU legislative process, the European Parliament's ECON Committee has adopted its report on the review of the Sustainable Finance Disclosure Regulation and approved the mandate to open trilogue negotiations with the Council. Parliament has now announced its mandate, with the first trilogue meeting between Parliament, Council and the Commission expected to take place shortly in October.

On 30 September 2026, the EU General Court ruled on a challenge brought by three environmental NGOs against the technical screening criteria for aviation and maritime transport under the EU Taxonomy, adoptedby the European Commission in 2023. The NGOs had asked the Commission to withdraw the criteria allowing certain conventional aircraft and gas-fuelled vessels to count as "transitional" sustainable activities. The Commission refused in June 2024. The NGOs took the refusal to the EU General Court.

Linklaters has advised the joint lead managers and the trustee on the successful offering of approximately HK$20bn equivalent multi-currency digital green bonds by the Government of the Hong Kong Special Administrative Region (HKSAR Government) of the People’s Republic of China under the Government Sustainable Bond Programme. The offering, comprising tranches denominated in Hong Kong dollars, renminbi, US dollars and euros, has set a new record as the world’s largest digital bond issuance.

We advised the underwriters and lenders on the financing for Universities Superannuation Scheme (USS) in connection with its acquisition of 100 percent of VTG Rail UK from VTG GmbH. USS is one of the UK's largest pension schemes, managing approximately £84 billion in assets, with a significant portfolio of infrastructure and private market investments.

The Financial Conduct Authority has now finalised its UK Sustainability Reporting Standards (UK SRS) for listed companies — the UK-endorsed version of the ISSB's sustainability and climate standards. The FCA has moved away from the originally proposed mandatory climate reporting model in favour of a ‘comply or explain’ approach, echoing the broader trend of simplification seen in the EU's Omnibus package on the CSRD.

On 22 September 2026, the Hong Kong Monetary Authority (HKMA) issued a circularattaching, as annex 1, a new Supervisory Policy Manual (SPM) module GS-2 on Transition Planning (the GS-2). GS-2 elaborates on and supplements the existing GS-1 Climate Risk Management module.