The entry into 2026 represents a significant milestone in the field of environmental, social and governance (ESG) criteria for the European Union and the business environment. After a turbulent end to 2025, which was marked by the finalization of key legislative changes, 2026 becomes a period of implementation, strengthened surveillance and ambitious new initiatives resulting from the European Commission's work programme.

Legacy of 2025 and adjustments in reporting

At the end of 2025, a fundamental shift occurred with the adoption of the package Omnibus I, which amended the directives CSRD (on sustainability reporting) and CSDDD (on due diligence). The most significant changes included a reduction in the scope of these directives and an adjustment of their application dates. Despite these changes, large public-interest entities remain required to report for the financial years 2025 and 2026.

An important moment for 2026 is also revision of the delegated act on climate taxonomy, which comes into force in the first quarter. This revision introduces simplification measures that companies can apply retroactively for the financial year 2025, or choose to apply them only from 2026. In addition, the adoption of the second quarter of 2026 is expected revised European Sustainability Reporting Standards (ESRS), which should clarify double significance and reduce the number of data points reported.

Climate, energy and deforestation

In the field of nature conservation, the end of 2025 brought an important postponement. The EU Regulation on deforestation (EUDR), which was originally due to apply earlier, has been postponed by one year, with the new date of application set at December 30, 2026. The European Commission is to examine the possibilities of simplifying this regime by April 2026.

The year 2026 will be rich in legislative packages in the energy sector:

• Energy omnibus (Q2 2026): It will focus on simplifying regulations on energy products.
• Energy Union Package (Q3 2026): It will create a framework for CO₂ transport infrastructure and renewables.
• Climate package (Q3/Q4 2026): It will bring a revision of the Emissions Trading System (ETS) for aviation and maritime transport.
• European Integrated Framework for Climate Resilience (Q4 2026): Its aim is to strengthen Member States' preparedness for climate change and remove financial barriers to investments in resilience.

Sustainable finance and circular economy

The financial sector will face stricter supervisory rules in 2026. External evaluators of European green bonds must register with ESMA by 21 June 2026, otherwise the bonds issued risk not meeting the requirements of the regulation. From July 2026, the ESG ratings oversight, with the providers of these ratings having to announce their intention to apply for authorisation during the third and fourth quarters.

The launch is expected in the third quarter Circular Economy Act, which will set horizontal standards for the design, reparability and recyclability of products. This law will be followed up by the end of the year Ocean Law, focused on marine habitat restoration and sustainable maritime economy.

Social agenda and litigation

The social pillar of ESG will be strengthened in 2026 with two proposals expected in Q4: The Digital Justice Act, which fights against manipulative interface design, and The Quality Jobs Act, aimed at protecting workers in the modern economy.

Attention will also be focused on the Dutch courts, where a decision in the dispute is expected in January 2026. Greenpeace v. Netherlands on the protection of the people of Bonaire. Strategic cases against companies will also continue Shell a ING Bank, which can define the scope of the private sector's obligations in the fight against climate change.

2026 thus confirms that the ESG landscape in the EU remains dynamic and requires businesses to be constantly prepared for new legal developments in areas ranging from financial transparency to social justice. JRi&CO2AI