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The IEJ and #PTG argue that the draft SRD grant regulations are regressive and fail to meet government commitments to 'extend and improve' social assistance. They highlight a 50% exclusion error rate and criticize the decision to freeze the grant at R350, which they claim is unlawful and irrational given inflation. The submission proposes a two-phase increase: first to R530 to align with the Child Support Grant, and later to the Food Poverty Line of R760. Additionally, they oppose new regulations regarding the recovery of irregular payments and the cancellation of applications for 'untraceable' applicants, arguing these shift the blame for systemic administrative failures onto vulnerable beneficiaries.

The document critiques Draft 1 of Mozambique's proposed Land Law, stating it enables land privatisation, restricts access to 'unavailable land', and lacks legal guarantees for community decision-making and protection against forced displacement. It highlights that previous consultations were inadequate, reaching only approximately 75,000 people out of a population of 32 million, and urges citizens to exercise their constitutional right to participate in the reform process.

The Procurement Reform Working Group (PRWG) criticizes the Public Procurement Bill 2023, asserting that it was rushed through Parliament with inadequate consultation and contains flaws that could amplify corruption and economic instability in South Africa. The group highlights the erosion of integrity provisions, the failure to implement Zondo Commission recommendations, and the introduction of a vague preferential procurement chapter that may lead to operational chaos and litigation.

The Stockholm Environment Institute warns that the EU Critical Raw Materials Act may exacerbate human rights breaches and 'green colonialism' in the Sámi homeland. While welcoming the inclusion of the UN Declaration on the Rights of Indigenous Peoples and FPIC in the draft, the authors argue these are insufficient due to gaps in national legislation in Sweden and Finland, the potential for weak certification schemes, and the lack of resources for Sámi communities to engage with fast-tracked licensing. They propose an EU-level oversight mechanism, stricter certification standards requiring FPIC, and a funding mechanism to support affected rights-holders.

The Public Affairs Research Institute and Corruption Watch argue that the Draft National State Enterprises Bill 2023 fails to provide adequate safeguards against political interference in the appointment of state-owned enterprise (SOE) boards. They propose adapting the Zondo Commission's recommendations by establishing a statutory 'integrity' appointment and oversight committee to vet candidates for the proposed holding company. The authors further contend that the Bill lacks clear timelines for transferring entities to the holding company and fails to provide the comprehensive primary legislation needed to resolve systemic governance failures in South Africa's SOEs.

The submission argues that the Electricity Regulation Amendment Bill [B23 – 2023] lacks sufficient provisions for a just transition, energy decentralisation, and transparency. It specifically criticises the potential for grid privatisation through wheeling agreements, the lack of regulatory support for energy storage and small-scale embedded generation (SSEG), and the expansion of Ministerial discretion over the Integrated Resource Plan (IRP) and procurement processes. The authors also object to proposed confidentiality clauses that could limit public access to licence applications and call for stronger public participation requirements aligned with PAJA and PAIA.

The Joint Strategic Resource (JSR) submits that the Public Procurement Bill 2023 remains rooted in an 'administrative paradigm' that prioritizes rigid compliance over procurement outcomes. The JSR argues that the Bill fails to clearly define the 'public procurement system' or the authority for preferential procurement policy, potentially violating section 217 of the Constitution. They advocate for a 'strategic procurement paradigm' that grants accounting officers more flexibility to tailor purchasing strategies to specific project needs and suggests that the Bill should embed clear procurement principles at the statutory level rather than relying on National Treasury instructions.

PARI argues that the Public Procurement Bill 2023 misinterprets Section 217 of the Constitution, particularly regarding preferential procurement, and risks legal instability by deferring too much substance to unpublished subordinate instruments. The submission proposes specific rewrites to Section 17 to ensure a mandatory national legislative framework for economic development and local content. It further recommends strengthening whistleblower protections, expanding automatic exclusions for political office-bearers, and clarifying access and disclosure clauses to prevent the Bill from becoming a 'secrecy clause'.

ClientEarth argues that the proposed FMP for mixed flatfish in the Southern North Sea and Eastern Channel lacks binding commitments and fails to adhere to the precautionary and ecosystem-based objectives of the Fisheries Act 2020. The submission specifically calls for fishing limits to be set below Maximum Sustainable Yield (MSY) to build climate resilience, the recovery of the depleted witch stock, and the implementation of firm Minimum Conservation Reference Sizes (MCRS) and towed gear measures.

The document argues that the Upstream Petroleum Resources Development Bill (B13 - 2021) is fatally flawed because it seeks to "accelerate exploration and production" of oil and gas, which contradicts South Africa's climate commitments and the global goal of net zero by 2050. The authors highlight significant administrative shortcomings, specifically the lack of a clear definition for "interested and affected party" (IAP) and inadequate consultation requirements for most application types. Furthermore, the Bill is described as being in conflict with the One Environmental System (OES) by attempting to legislate on environmental matters that fall under the exclusive purview of the Minister for Forestry, Fisheries and the Environment. The submission also calls for the incorporation of Free, Prior and Informed Consent (FPIC) and a robust Social and Labour Plan (SLP) framework to protect vulnerable communities from the health and economic risks associated with petroleum extraction.

A coalition of environmental organisations opposes the Swedish EU Presidency's effort to delete Article 16 from the proposed Nature Restoration Law, which would have granted citizens and NGOs the right to challenge the legality of national restoration plans. The signatories argue that relying on recitals or the Aarhus Convention is insufficient due to inconsistent compliance across EU Member States and the risk of irreparable environmental damage, as seen in Poland and Romania.

ClientEarth warns that the UK government is in breach of the Environment Act 2021 due to missed deadlines for environmental targets and the Environmental Principles Policy Statement. The organization argues that these delays, combined with the 'sunset' provisions of the Retained EU Law Bill, risk a governance gap where EU-derived environmental protections are revoked before domestic replacements are fully operational.

ClientEarth warns that the UK Government's move toward rapid deregulation, particularly via the Retained EU Law (Revocation and Reform) Bill, risks a 'perfect storm' of environmental degradation and reduced business investment. The organization argues that the Bill could lead to the overnight disappearance of critical legislative frameworks protecting air, water, and biodiversity by December 31, 2023, while bypassing parliamentary scrutiny through secondary legislation. This shift is viewed as a contradiction of the Government's own manifesto commitments and legal obligations under the Climate Change Act 2008.

Earthjustice criticizes the Biden administration for defending a Trump-era policy that overturned a 2016 coal-leasing moratorium. Despite a court ruling that the decision to end the moratorium failed to account for climate impacts, the administration continues to process new lease applications while U.S. coal consumption rose 14% in 2021. The document highlights that as of 2021, the Bureau of Land Management (BLM) administered 299 federal coal leases across approximately 458,600 acres, and over 40% of U.S. coal is produced on public lands. Earthjustice calls for the administration to internalize the environmental and social costs of mining and to stop defending resource management plans in the Powder River Basin that ignore the public health impacts of burning publicly-owned coal.

ClientEarth asserts that the Energy Charter Treaty (ECT) obstructs climate policy by allowing fossil fuel companies to sue governments for compensation over environmental regulations. The organization argues that recent 'modernisation' efforts are insufficient, as they maintain a 'flexibility mechanism' that would allow litigation until the late 2030s and include protections for biomass and carbon capture. The document calls for a coordinated withdrawal of the EU, its member states, and the UK to eliminate the 'chilling effect' of the treaty on the European Green Deal and other climate commitments.

The Centre for Environmental Rights (CER) argues that the Climate Change Bill requires stronger enforcement mechanisms, more ambitious emissions targets, and greater transparency to effectively address the climate crisis in South Africa. The CER emphasizes that climate change is a human rights and gender justice issue, noting that women and girls face disproportionate risks. Key recommendations include the introduction of criminal and administrative penalties for exceeding carbon budgets, the adoption of a 'near zero' emissions target by 2050, and the creation of a public web-based information portal for climate data. The CER also calls for more inclusive public participation, particularly for remote communities, youth, and women, and suggests establishing an inter-departmental body to coordinate the climate response across government.

The International Institute for Sustainable Development (IISD) analyzes the 2022 Switzerland-Indonesia Investment Promotion and Protection Agreement (API). While noting innovations in limiting 'treaty shopping' and excluding speculative profits from expropriation compensation, the IISD argues the agreement remains problematic. Key concerns include a climate-neutral definition of investment, unpredictable 'fair and equitable treatment' standards, insufficient protections for the state's right to regulate in the public interest, and a dispute settlement mechanism that allows direct access to international arbitration without exhausting national remedies. The IISD recommends that Switzerland adopt more stringent sustainability criteria and stronger investor responsibility mechanisms in its future treaties.

ClientEarth submits that while ELMS has potential, it cannot replace mandatory agri-environmental regulations. The organization warns that withdrawing 'cross compliance' without a successor framework will create significant protection gaps in soil and water quality, as the voluntary nature of ELMS and the poor enforcement record of the Environment Agency are unlikely to maintain basic environmental standards.

ClientEarth argues that the proposed amendments to the RRF Regulation to support REPowerEU create an unlawful 'preferential treatment' for fossil gas and oil infrastructure. The organization contends that the Commission bypassed the TEN-E Regulation's transparency requirements by relying on a 'wish list' from the industry-led ENTSOG, and that exempting these projects from the 'Do No Significant Harm' (DNSH) principle violates EU environmental law and the European Climate Law. ClientEarth further asserts that the lack of impact and climate assessments for the proposal is unjustifiable, regardless of the urgency of energy security needs.

IISD experts assert that the modernized Energy Charter Treaty (ECT) fails to align with climate ambitions, specifically noting that the European Union and United Kingdom have agreed to maintain investment protections for existing fossil fuel assets for at least 10 years after the treaty enters into force. This allows fossil fuel investors to continue filing investor–state dispute settlement (ISDS) claims, potentially hindering the phase-out of oil and gas required to limit warming to 1.5°C. Consequently, several EU member states have announced plans to withdraw from the treaty, leading the European Commission to propose a coordinated EU-wide exit to avoid fragmented unilateral withdrawals.