Horizon - ESG Regulatory News and Trends

Welcome to Horizon, DLA Piper’s regular bulletin reporting on late-breaking legislative and policy developments in ESG. Our aim is to scan the litigation, enforcement, and regulatory horizon to help inform business decisions.

In this issue

Click each topic to jump to that section.

Disclosures
Greenwashing
Climate change and the environment: Regulatory and Enforcement
Climate change: Litigation
Climate change: The marketplace
Supply chain
Business and human rights
ESG investment
ESG calendar – key reporting deadlines, coming events

DISCLOSURES

California emissions reporting disclosures will not be postponed. Implementation of California's GHG emissions reporting requirements will move ahead as originally planned, with initial disclosures due in 2026. A proposal to delay implementation of the disclosures by two years, championed this summer by Governor Gavin Newsom, was ultimately omitted from the budget-related bill passed by state legislators on August 31. The compliance deadline for companies has not changed. However, SB 219 has survived, giving the California Air Resource Board until July 1, 2025 (rather than January 1, 2025) to finish its rulemaking and adopt regulations for reporting entities’ annual disclosures of Scope 1-3 emissions.

NAIC adopts first climate financial impact analysis for P&C insurers. The National Association of Insurance Commissioners (NAIC) has adopted the first US climate financial impact analysis exercise for US property and casualty (P&C) insurers. On August 15, the NAIC adopted RBC proposal 2024-20-CR MOD, which requires P&C insurers to model and disclose climate impact on hurricane and wildfire exposures for year end 2024, 2025, and 2026 on the insurer’s risk-based capital filing. The disclosures are for informational purposes only and not to determine a new RCAT (Risk-Based Capital for Catastrophe Risk) charge. The RBC proposal was based on a referral from the Solvency Workstream of the Climate & Resiliency (EX) Task Force, which was directed by the executive committee to develop a climate scenario analysis appropriate for the US market. The CRTF proposal was modified by the Financial Condition (E) Committee at the request of industry to provide more flexibility in how financial impacts can be modeled. To learn more about this development, contact Kathleen Birrane.

Australia advances climate reporting requirements. Taking the last legislative step toward enactment, on September 9 Australia’s House of Representatives passed the Treasury Laws Amendment bill, mandating climate-related reporting requirements for large and medium-sized companies. Initial reporting for the largest companies will begin in January 2025. The Australian Accounting Standards Board is continuing to develop climate disclosure standards, in alignment with the IFRS Foundation’s International Sustainability Standards, for Australian companies. In a related move, the House also voted to establish the Net Zero Economy Authority, which will steer Australia’s economic transformation to net zero emissions.

PAFA board approves strategy for groundbreaking Centre of Excellence for Sustainability to enhance ISSB standards across Africa. The board of the Pan African Federation of Accountants (PAFA) has officially approved a strategy to establish a Centre of Excellence (CoE) for Sustainability. This initiative aims to advance the adoption and implementation of the IFRS Sustainability Disclosure Standards of the International Sustainability Standards Board throughout the continent, including governance, transparency, and sustainable value creation. The CoE will function as a central resource hub for professional accountancy organizations and their members across Africa, offering tailored, multilingual resources to expedite the adoption of ISSB standards and bolster sustainability.

GREENWASHING

New guidelines from USDA’s FSIS on environmental labeling claims. The US Department of Agriculture’s Food Safety and Inspection Service (FSIS) has released updated guidelines regarding the substantiation of animal-raising and environment-related claims on meat and poultry product labels. The guidelines, effective as of August 2024, aim to enhance transparency and prevent greenwashing, making it clear that companies are expected to substantiate animal welfare, animal pedigree, and environmental claims for meat and poultry product labels with supporting documentation or third-party certification. Our alert covers the key points.

EPA expands mandatory federal purchasing program. In April this year, the US Federal Acquisition Regulation (FAR) was amended to require that agencies “procure sustainable products and services… to the maximum extent practicable.” Now, the EPA is expanding its Recommendations of Specifications, Standards and Ecolabels for Federal Purchasing Program to reflect this, including new categories of products and services, including healthcare, laboratories, clothing and uniforms, and cafeteria and food service products. This expansion will have a downstream effect on federal procurement practices, as FAR requires that agencies purchase products and services that meet the requirements of the Recommendations Program. See our alert.

Blue Triton microplastics case put to rest. Slowinski v. BlueTriton Brands, Inc., a putative class action, charged that the defendant’s use of the phrase “100% Natural Spring Water” on its Ice Mountain bottled water was misleading because the water allegedly contained microplastics. In August, the District Court for the Northern District of Illinois granted BlueTriton’s motion to dismiss the case, in an opinion notable for its thorough analysis of federal preemption and its colorful dissection of the plaintiffs’ case. Although the court left room for the plaintiffs to refile an amended complaint, it has summarily rejected their effort to do so and has dismissed the action with prejudice.

Landmark South African decision finds a social media campaign misleading. In South Africa’s first decision on corporate greenwashing, the country’s Advertising Regulatory Board (ARB) has ruled that a TotalEnergies social media campaign, #FuelYourExperience, is misleading. The campaign emerged from the long partnership between TotalEnergies and Sanparks, the South African conservation authority, to promote the country's national parks. In the campaign, TotalEnergies said it is "committed to sustainable development and environmental protection.” The company stated, "That's why we have partnered with Sanparks for over 60 years, so that South Africans can appreciate our country's natural heritage and pass on a love for the environment to their children. The ARB said these statements could lead people to believe TotalEnergies practices “sustainable development” in all its operations, adding there is "no evidence that there is a link between the support of Sanparks, and any definition of sustainable development.”

UK FCA extends compliance date for compliance with naming and marketing rules to April – in exceptional circumstances. The UK’s Financial Conduct Authority (FCA) will allow some asset managers “limited temporary flexibility” to comply with the Sustainability Disclosure Requirements’ naming and marketing rules – extending the compliance date, in certain circumstances, from December 2, 2024 to April 2, 2025. It is allowing the extension for UK-authorized investment funds only in exceptional circumstances, when funds have already been working to comply with the requirements and have submitted a completed application seeking approval of amended disclosure for that fund by October 1, 2024. Funds that use terms like “sustainable,” “sustainability,” or “impact” in their names will be eligible for the extension. FCA added, “We also expect firms to comply with the rules as soon as they can, without waiting until April 2, 2025.”

CLIMATE CHANGE AND THE ENVIRONMENT: REGULATORY AND ENFORCEMENT

SEC dissolves Climate and ESG Task Force. The SEC appears to have quietly disbanded its Enforcement Division’s Climate and ESG Task Force a few months ago, an agency spokesperson told Bloomberg Law. The task force, formed in March 2021, worked for three years to bring litigation regarding misstatements and material gaps in climate risk disclosures and violations of related policies and procedures under existing SEC rules. While this agency action may signal a cooling off of SEC’s efforts to pursue enforcement action related to public companies’ ESG disclosures matters, some observers are commenting that, in the long run, the disbanding of the task force may have little effect. Recent SEC enforcement actions indicate there is no reason to believe the agency will stop pursuing alleged greenwashing offenders, and public companies should continue to pay very close attention to the strength of their disclosure controls and procedures with respect to all of their public disclosures, within or outside SEC filings.

SEC fines Keurig. Keurig Dr Pepper Inc., manufacturer of single-serve coffee systems, will pay the SEC a $1.5 million civil penalty to settle SEC charges that the company made misleading claims about the recyclability of its plastic K-Cup pods in its annual reports on Form 10-K. The pods “can be effectively recycled,” Keurig said in its 2019 and 2020 filings. However, in its September 10, 2024 press release, the SEC stated that “Keurig did not disclose that two of the largest recycling companies in the United States had expressed significant concerns to Keurig regarding the commercial feasibility of curbside recycling of K-Cup pods at that time and indicated that they did not presently intend to accept them for recycling.” Since 2020, Keurig has disclosed that its pods, now made of #5 plastic, have been fully recyclable; a note on its packaging, however, exclaims that the pods are “not recycled in many communities.” While the amount of the fine is small, it signals that financial regulators may be increasingly focusing on disclosures relating to a company’s environmental and sustainability claims that may have an impact on shareholder value. Keurig has agreed to pay the fine without admitting or denying the agency’s findings.

Inflation Reduction Act grants will support updating building codes. The US Department of Energy has announced $240 million in grants to 19 state and local governments to help them encode modern building performance standards that address energy efficiency and decarbonization. The selected programs, announced on August 27, will be funded by the Inflation Reduction Act, and variously include such goals as lowering energy costs, reducing GHG emissions, developing the workforce, making housing more affordable, and addressing the needs of disadvantaged communities. See those selected for grants here.

Newsom signs one major environmental bill; two more await his signature. On September 22, California Governor Gavin Newsom signed into law SB 1053, which updates a 2014 law to totally ban stores from providing plastic bags. The bill aims to encourage shoppers to bring their own reusable bags. Stores will be permitted to provide only bags made from recycled paper at checkout, for which they must charge at least 10 cents. The bill goes into effect January 1, 2026.

Awaiting the governor’s signature are two other major bills. Governor Gavin Newsom has until September 30 to sign them into law. They are:

• SB 707, the Responsible Textile Recovery Act, will mandate manufacturers, brand owners, distributers, and retailers of apparel or textiles to create and fund a producer responsibility organization (PRO) that would manage textile collection, sorting, and recycling. Like the plastics and packaging extended producer responsibility (EPR) law in California, this statewide program would be overseen by the California Department of Resources Recycling and Recovery (CalRecycle). SB 707 would require the PRO to conduct a statewide needs assessment by March 1, 2027, and would require CalRecycle to adopt implementing regulations with an effective date no later than July 1, 2028. The act’s current text reflects lengthy negotiations with textile and recycling industry stakeholders. A number of manufacturing groups have expressed concerns about who will ultimately pay for the program and have noted a perceived “loophole for online marketplaces” that could allow them to avoid paying into the PRO. SB 707 is one of several EPR laws passed in California this session and sent to Governor Newsom’s desk; others include SB 1143 (EPR for paint), AB 863 (update to the EPR for carpet program), and SB 1066 (EPR for marine flares). See our roundup of state EPR laws.

• AB 660, food date labels: It is estimated that at least 20 percent of food waste arises from confusion over expiration dates on food packaging. This law aims to reduce food waste by clarifying confusing, inconsistent expiration dates on food packaging. It codifies already familiar terminology: “best if used by” or “best if used or frozen by” will indicate the quality date, while “use by” or “use by or freeze by” will indicate the safety date.

Chicago advances ordinance mandating data center environmental impact study. A key Chicago city council committee has advanced an ordinance directing city departments to study the environmental and energy impacts of data centers within Chicago. The primary purpose of the ordinance is to provide bid preference to vendors who agree to store city data at facilities in the city - but, in response to concerns of environmental activists, the ordinance would mandate the creation of an interdepartmental working group that would review the environmental and energy impacts of data centers inside Chicago. Our alert tells you more.

An Australian state moves to decarbonize infrastructure delivery. Traditionally, public infrastructure procurement is evaluated via three criteria - cost, quality, and time. New South Wales, Australia's most populous state, is adding a fourth: embodied carbon, described by Infrastructure Australia as the “emissions associated with materials and construction processes throughout the whole lifecycle of an infrastructure or building asset, including material extraction, transportation, manufacturing, construction, use, replacement, demolition and end of life.” See our alert.

Singapore introduces Energy Transition Bill. With the goals of decarbonizing the power sector and maintaining a stable energy supply during emergencies, Singapore’s Ministry of Trade and Industry (MTI) has introduced a new energy transition bill for first reading in Parliament. The Energy Transition Measures and Other Amendments Bill would update three existing laws – the Gas Act, Electricity Act, and Energy Market Authority of Singapore Act – to address energy security and advance sustainability. It would create a Future Energy Fund, with $5 billion in funding to support energy transition investments. The Energy Market Authority (EMA) will have oversight of a new agency, the Central Gas Entity, and, in a move with implications for LNG procurement, power generation companies will be required to procure gas solely from this agency. The EMA will also have the authority to ration use of power during emergencies. Noting that about 40 percent of Singapore’s carbon emissions come from power generation, primarily from natural gas, the MTI stated, “Developing different decarbonization pathways will change our energy landscape significantly, including in the way we regulate energy markets and develop our energy infrastructure.” Singapore is aiming to achieve net-zero emissions by 2050. The bill’s six key proposals may be seen here.

IMO striving to cut GHG emissions in shipping. The UN’s International Maritime Organization (IMO) has been working toward the ambitious emissions reduction targets its 176 member states set last year in its 2023 IMO Strategy on Reduction of GHG Emissions from Ships- that is, to reduce CO2 emissions from maritime transport, as an average across international shipping, by at least 40 percent. Currently, the IMO is working to develop an impact assessment, a maritime fuel standard – part of the mechanism for determining the GHG limits ships may emit – and a system of fee incentives. Unusually, this month and next month member states are meeting three times to hammer out the implemented regulations. They met early in September to workshop impact assessments of the proposed measures, then at a 17th intercessional meeting in mid-September, and will convene again in October during the 82nd meeting of the Marine Environment Protection Committee (MEPC). These gatherings will produce a final agreement, which member states will then need to review. Even that process will be unusually accelerated: observes are expressing hope that the measures will be ready to present to MEPC for approval at its spring 2025 meeting.

CLIMATE CHANGE: LITIGATION

Suit says Texas anti-ESG law violates the Constitution. Texas SB 13 requires the state to divest any investments from financial firms that are allegedly boycotting fossil fuels. On August 29, the American Sustainable Business Council filed suit against the State of Texas, alleging that SB 13 “should be declared unconstitutional and unenforceable because it impermissibly infringes rights of free speech and association” in violation of the First and Fourteenth Amendments. The law, the suit adds, imposes vague requirements, is “based on no legitimate state interest,” and has harmed the Texas economy. The litigation is already being watched for its potential to overturn similar laws in other states, such as West Virginia and Kentucky, which generally premise that when financial firms take climate change into account, they are pursuing a leftist social agenda. A similar law in Oklahoma law was permanently blocked earlier this year. In early August, the US District Court for the Western District of Missouri permanently blocked Missouri’s “Anti-ESG Rules,” promulgated by the Missouri Securities Division.

Chamber of Commerce v CARB – hearing postponed. A hearing on the parties’ dispositive motions in Chamber of Commerce of the United States of America, et al. v. California Air Resources Board, federal litigation challenging the constitutionality of the two California climate disclosure laws (SB253 and SB261), has been postponed to October. It now appears likely that the case may not be decided before January 1, 2025, when a key requirement for some companies to begin measuring their GHG emissions kicks in.

South Korea’s top court: climate action is a legal duty. In a landmark ruling issued on August 29, South Korea’s Constitutional Court found that the South Korean government’s unambitious climate targets are unconstitutional because they fail to protect the rights of future generations. South Korea currently has no legally binding targets to cut greenhouse gas emissions between 2031 and 2049. Stating that “legislators have the duty and responsibility to make concrete laws for mid- and long-term greenhouse gas reduction plans,” the court has given the government until February 2026 to set firm carbon-reduction targets for 2031 and beyond. The case, Woodpecker et al. v. South Korea, is being seen as significant not just for its impact on South Korea but as an important precedent for the Asia Pacific region, where similar cases are moving forward in Japan, Taiwan, and Indonesia. The case was initially brought in 2020 by The Youth 4 Climate Action and was ultimately consolidated with three other suits. Lead plaintiff Woodpecker, at the time the suit was filed, was a 20-week-old fetus.

Irish High Court to hear case on Climate Action Plan 2024. The High Court of Ireland on September 9 granted leave to a group of applicants – Community Law & Mediation (CLM), a community law center based in Dublin and Limerick, along with a grandfather, a youth climate activist, and a child – who are asking the court to declare that the government’s Climate Action Plan 2024 (CAP24) does not comply with the Climate and Low Carbon Development Act 2015 and thus undermines the country’s climate action efforts. CAP24 sets out Ireland’s roadmap for meeting its legally binding carbon budget. The plaintiffs also allege that CAP24 violates the fundamental rights of the three individual applicants, the marginalized groups CLM assists, and future Irish generations, as protected by the Constitution of Ireland, the European Convention on Human Rights, and the EU Charter of Fundamental Rights. A separate challenge brought by Friends of the Irish Environment concerning Climate Action Plan 2023 is also moving through the courts.

CLIMATE CHANGE: THE MARKETPLACE

Consumers are prioritizing sustainability – CEOs? Not so much. Consumers are becoming increasingly concerned about climate change, and in particular the part they play in it, and are looking to brands and retailers as well as governments for guidance in their sustainability journey – but, according to a report from global consultancy Bain & Company, CEOs meanwhile are shifting their focus away from sustainability to other pressing concerns. “Sustainability still matters,” observes The Visionary CEO’s Guide to Sustainability 2024, “but companies are struggling to meet their existing commitments.” That changed focus, the report finds, arises as business leaders come to understand that the transformation to sustainability will more difficult or take longer than expected. “Many sustainability efforts are currently in this trough,” the report says. At such a point, “visionary pragmatism is needed more than ever.” “Sooner than expected,” the report states, “a mix of new technologies, consumer and customer behavior, and smart policy will create valuable opportunities for the most forward-thinking companies across industries.”

Greening commercial leases. Many large companies have reported that they are not sufficiently prepared to meet emerging climate-risk reporting and verification requirements, nor are they prepared to take advantage of climate-related opportunities. “Greening” your commercial leases - establishing legally enforceable cooperation between building owners and tenants to address climate risks and climate reporting requirements - can be a key starting point in the sustainability journey. Our alert tells you more.

SUPPLY CHAIN

European Union Deforestation Regulation: What US companies need to know . Due diligence requirements under the Regulation on Deforestation-Free Products (EUDR) will apply starting on December 30, 2024, setting in motion a landmark regulation to prevent products linked to deforestation and forest degradation from being placed on the EU market. The EUDR effectively prohibits the import, sale, or export of certain commodities and derivatives within the EU unless they are deforestation-free, produced in accordance with relevant local laws in their country of production, and covered by a due diligence statement submitted electronically to an information system accessible to competent and customs authorities. See our alert.

Asian countries, Australia to establish supply chain for sustainable fuels. Japan, Australia, and nine Southeast Asian countries have agreed to establish an extensive Asian supply chain geared to the production and distribution of sustainable fuels, with a particular focus on biofuels and other renewable fuels. This agreement was established in August during the second Asia Zero Emission Community Ministerial Meeting in Jakarta. Among the agreement’s goals: developing a roadmap to establish supply chains for sustainable fuels and leveraging renewable resources to power the net zero transition.

World Uyghur Congress case ruling: A new challenge for supply chains? In a landmark ruling, the UK Court of Appeal has clarified that the provision of “adequate consideration” at some point in the supply chain does not prevent goods imported into the UK from being identified as criminal or recoverable property under the Proceeds of Crime Act 2002. The case, brought by the World Uyghur Congress, arises from concerns about cotton imports entering the UK from the Xinjiang Uyghur Autonomous Region in the People’s Republic of China. The court’s decision contradicts previous understanding and could have far-reaching implications for businesses. Find out more in The Global Anti-Corruption Perspective.

BUSINESS AND HUMAN RIGHTS

California AB 3234 – social compliance audits on use of child labor. In addition to the three environmental bills we cover in this month’s Regulatory section, also awaiting California Governor Newsom’s signature is AB 3234, which would require employers who have voluntarily undergone social compliance audits about the use of child labor in their business to post, on the company website, a clear, obvious link to an online report detailing the latest audit’s findings. “Social compliance audit” is defined as an inspection of any factory, production house, farm, or packaging facility operated by a business to verify its compliance with social and ethical responsibilities as well as health and safety regulations regarding child labor. Among the requirements to be set out in the online report: whether the business engages in child labor, whether the business exposes children to hazardous or unsafe workplace situations, and whether children work within or outside regular school hours or during night hours. Notably, businesses would not be required to carry out such social compliance audits – the process remains voluntary.

Florida’s HB 1331 – contractors required to make certifications addressing forced labor. Florida’s landmark HB 1331, now in effect, requires companies seeking to provide commodities to state and local governments in Florida to certify that their products are not made with forced labor. The certification must be provided to the Florida Department of Management Services (DMS), in writing, by a member of the company’s senior management. Failure to complete this certification – which entails a process of due diligence to ensure the human rights integrity of the supply chain – may result in the company being ineligible to contract with the state. Furthermore, HB 1331 requires the DMS to create and maintain a publicly available Forced Labor Vendor List identifying companies that have been disqualified from public contracting due to their failure to make the required certification. Companies that falsely certify compliance with HB 1331 or make the certification but should have known that there was forced labor in their supply chain shall be assessed the greater of a $1,000 fine or an amount equal to 20 percent the value of the commodity provided under the contract. To learn more, please contact Andrew Current or Tom Daley.

South Korea: CEOs arrested. South Korea is seeing the first arrests of company leadership under its Serious Accident Punishment Act. On August 29, Park Soon-kwan, CEO of the lithium battery manufacturer Aricell, and his son Park Joong-eon, head of factory management, were arrested and charged with violating the act in the wake of a fire at a battery plant in June in which 23 workers – most of them migrants – died. The investigation into that fire has been in the news in South Korea all summer. In early August, the Ministry of Labor and Employment announced tighter safety regulations and support measures for manufacturing facilities in an effort to protect foreign employees. On August 23, police investigating the fire said the company, pushing to fulfill a major contract, had rushed production, ignored signs of danger, and provided no safety training to employees, many of whom were not fluent in Korean. More largely, it appears that enforcers may no longer be reluctant to deploy the Act, which entered into law in 2022. Also on August 29, Park Young-min, CEO of zinc producer Yeongpoong Seokpo, and another senior staff member were arrested on charges arising from an accident at a company refinery last year.

ESG INVESTMENT

Euronext announces ESG financial tools and initiatives. Pan-European stock exchange Euronext is launching a set of ESG investing and sustainability initiatives and tools that it hopes will accelerate the transition to sustainable finance. Among the programs, announced on September 9 during Euronext Sustainability Week, are a tool to help listed companies benchmark their ESG performance relative to peers and an ESG Advisory Service to help small and medium-sized enterprises implement the EU’s Corporate Sustainability Reporting Directive (CSRD) disclosure requirements. Euronext also announced the new Euronext Sustainable Network, being created to establish a collaborative ecosystem of sustainable finance market participants across Europe - banks, auditors, carbon brokers, advisory companies, law firms, data providers, and investment firms.

ESG CALENDAR – KEY REPORTING DEADLINES, COMING EVENTS

Deadlines

• US: California Transparency in Supply Chains Act – annually based on the company’s internal annual publication deadline
• Canada: Bill S-211, Fighting Against Forced Labor and Child Labor in Supply Chains Act – annually on May 31
• EU: Taxonomy Regulation
  • NFRD obliged companies – financial years starting on or from January 1, 2024 (with reports due in 2025/2026)
  • Large undertakings and parents of large groups – financial years starting on or from January 1, 2025 (with reports due in 2026)
• EU: Corporate Sustainability Reporting Directive (CSRD)
  • Large EU Public Interest entities (NFRD obliged) – January 1, 2024 (with reports due in 2025) and then annually
  • Large EU undertakings and parents of large EU groups – January 1, 2025 (with reports due in 2026) and then annually
  • Non-EU parent companies – January 1, 2028 (with reports due in 2029) and then annually
• EU: Deforestation Regulation – the regulations will substantively apply from December 30, 2024 onwards.
• EU: Corporate Sustainability Due Diligence Directive (CSDDD)
  • 2027 for companies with 5,000+ employees and €1.5 billion
  • 2028 for companies with 3,000+ employees and €900 million net turnover and
  • 2029 for all other companies that fall within the scope of the CSDDD.
• UK: Modern Slavery Act, Transparency in Supply Chains Act – annually. Companies should publish their statement as soon as possible after their financial year end, which is expected to be, at most, within six months of the organization’s financial year end. Companies may wish to publish these statements at the same time as they publish other annual accounts.
• Germany: Act on Corporate Due Diligence Obligations in Supply Chains
  • Phase 1 – June 1, 2025
  • Phase 2 – annually on January 1
• Switzerland: Due Diligence and Transparency in Relation to Minerals and Metals from Conflict-Affected Areas and Child Labor – annually on June 30
• Norway: Transparency Act – annually on June 30
• Australia: Modern Slavery Act
  • If the business reporting date is based on calendar year (ie, January 1 to December 31), then the reporting deadline is annually on June 30
  • If the business reporting date is based on Australian financial year (ie, July 1 to June 30), then the reporting deadline is annually on December 31
  • If the business reporting date is based on Foreign Financial Year – including United Kingdom and Japan (ie, April 1 to March 31) – then the reporting deadline is annually on September 30
• Australia: Climate-Related Financial Disclosures
  • Group 1: January 1, 2025 is start date for first year’s report, due January 1, 2026
  • Group 2: July 1, 2026 is start date for first year’s report, due July 1, 2027
  • Group 3: July 1, 2027 is start date for first year’s report, due July 1, 2028

Coming events

• Climate Week NYC takes place September 22-29, 2024 in New York City.
• World Conference on Climate Change & Sustainability takes place October 21-23 in Barcelona.
• The 2024 United Nations Biodiversity Conference of the Parties (COP16) to the UN Convention on Biological Diversity (CBD) will be held October 21 - November 1, 2024 in Cali, Colombia.
• 16th session of the UN Convention to Combat Desertification takes places December 2 – 13, 2024 in Riyadh.
• The 2024 United Nations Climate Change Conference (COP 29) will be held November 11 – 22, 2024 in Baku, Azerbaijan.
• The 13th United Nations Forum on Business and Human Rights will be held November 25 – 27, 2024, both hybrid and in-person in Geneva, Switzerland.