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The Clean Air Task Force (CATF) argues that the CFTC's withdrawal of guidance for voluntary carbon credit derivative contracts risks eroding market integrity and undermining climate progress. CATF highlights systemic quality issues in voluntary carbon markets, particularly in forest carbon credits, and contends that the withdrawal process lacked transparency and legal justification. The organization recommends that the CFTC not only reinstate the guidance but move toward issuing specific regulations for these markets.

Ten years after the Paris Agreement, French banks and insurers continue to heavily finance fossil fuel expansion, with some increasing their support for oil and gas extraction. The report argues that 'green finance' and ESG labels are largely greenwashing, as they fail to redirect capital away from climaticide activities. It further criticizes the French and European governments for favoring voluntary industry commitments over binding regulations and for weakening key directives like the CSRD and CSDDD under pressure from financial lobbies.

Reclaim Finance reports that asset managers are bypassing European Securities and Markets Authority (ESMA) guidelines on ESG fund naming to continue investing in fossil fuel developers. Analysis of 190 French-domiciled or managed funds shows nearly half changed names to avoid regulatory constraints. The document attributes these loopholes to lobbying by firms like BlackRock and Amundi and warns that similar gaps may be introduced into the revised Sustainable Finance Disclosure Regulation (SFDR).

Reclaim Finance analyzes EFRAG's proposal to reduce ESRS data points by 68%, warning that this limits comparability and data quality. The organization specifically criticizes proposed 'reliefs'—such as the 'undue cost or effort' filter—that could allow companies to avoid reporting material information. Additionally, the document argues that the standards fail to adequately address the financial sector, calling for more precise reporting on fossil fuel financing and the use of physical intensity targets rather than attribution-based metrics like PCAF.

Reclaim Finance argues that the European Commission's proposal to revive securitisation lacks safeguards against financing polluting activities and may hide climate-related risks. The organization proposes amendments to require investor due diligence on ESG risks, mandate disclosure of fossil fuel exposures, and either ban fossil fuel securitisation or impose high risk weights (up to 1250%) on such positions. It further suggests that the securitisation sub-committee publish ESG risk management guidelines and that future regulatory reviews explicitly assess the impact of securitisation on EU climate and environmental goals.

Since January 2025, one-third of funds previously holding the French ISR label have abandoned it rather than comply with new criteria excluding companies developing new coal, oil, or gas projects. Reclaim Finance argues this highlights the failure of voluntary labels and the persistence of greenwashing, noting that over 4,000 ESG-promoting funds are sold in France compared to only 967 ISR-labeled funds. The organization urges regulators to implement binding exclusions of fossil fuel development in the upcoming 2025 revision of the European Sustainable Finance Disclosure Regulation (SFDR) to protect investors and accelerate the financial transition.

CAPE supports the PMRA's effort to update fees but argues the proposed increases are inadequate for full cost recovery. The organization advocates for a fee structure based on the polluter-pays principle that incorporates health, environmental, and social costs, while opposing 'niche' product exemptions and discounts for high-volume registrants.

The French Financial Markets Authority (AMF) is adopting ESMA guidelines on ESG fund naming starting May 21, 2025, but Reclaim Finance argues these rules create uneven requirements that risk 'transition-washing'. The document notes a 24% decrease in 'Article 9' funds under SFDR due to reclassification to 'Article 8' to avoid sanctions. To combat greenwashing, the author proposes that the 2025 SFDR revision should mandate the exclusion of companies developing new fossil fuel projects for all funds claiming environmental or social objectives.

Reclaim Finance critiques the new ESMA guidelines adopted by the AMF for ESG fund naming, arguing they create unequal requirements that risk 'transitionwashing'. The organization urges that the 2025 revision of the Sustainable Finance Disclosure Regulation (SFDR) must mandate the exclusion of companies involved in fossil fuel expansion to ensure genuine sustainability and protect investors from misleading claims.

The IISD response to the DESNZ consultation argues for more rigorous standards in assessing Scope 3 emissions for offshore oil projects, specifically calling for the separate reporting of Category 11 emissions, the use of zero-emission baselines, and the assessment of significance based on 1.5°C science-based scenarios rather than as a proportion of global emissions.

The document criticizes the U.S. EPA and state governments for failing to regulate industrial PFAS discharges, which shifts cleanup costs to taxpayers. It proposes three primary actions: enforcing pretreatment requirements for Publicly Owned Treatment Works (POTWs), codifying Method 1633 for wastewater testing, and establishing Effluent Limitation Guidelines (ELGs) to mandate PFAS removal by industries.

The IEJ argues that the Social Relief of Distress (SRD) grant is plagued by a 50% exclusion error rate due to systemic barriers and budget constraints. The organization opposes proposed regulatory amendments—including the retention of the R350 grant value, the extension of the grant only until March 2025, and new punitive measures for fund recovery and payment cancellation—claiming these measures disregard digital exclusion and the diminishing real value of the grant.

The document outlines specific demands for the 'REACH 2' reform to address systemic data gaps in the EU chemical market. It argues that the original 'no data, no market' principle failed because registration requirements were too vague and did not cover all substances, such as polymers and low-tonnage chemicals. ClientEarth proposes expanding registration obligations, introducing new reporting duties for downstream users, and increasing transparency for investors and consumers regarding substances of very high concern (SVHCs).

ClientEarth argues that the TPT framework must move from permissive language to mandatory, science-aligned standards to correct a market failure where corporate net zero commitments lack credible transition plans. Key recommendations include requiring alignment with 1.5°C pathways, mandatory disclosure of all Scope 1-3 emissions, and a prohibition on counting carbon credits toward reduction targets. The document also advocates for stronger links between transition plans and financial statements, more rigorous reporting on corporate lobbying, and the integration of 'just transition' and nature-positive objectives.

ClientEarth's response to the FCA's CP22/20 proposes several enhancements to the SDR framework to ensure consumer protection and environmental integrity. Key recommendations include the adoption of a "do no significant harm" principle, the implementation of "double materiality" in reporting, and the tightening of criteria for "sustainable focus" and "sustainable improver" labels. The organization warns that the term "sustainable" may be misleading if products only target narrow objectives while causing harm elsewhere, and calls for a robust enforcement roadmap to oversee the self-certifying labelling regime.

ClientEarth argues that the HM Treasury's review of Solvency II fails to address climate risks and proposes several regulatory changes. Key recommendations include making investments in new fossil fuel exploration and development ineligible for the matching adjustment and requiring a 100% capital charge for such exposures to prevent stranded asset risks. The document also calls for mandatory, embedded transition plans for insurers, the adoption of 'double materiality' to manage the sector's impact on the environment, and formal Pillar 2 requirements for long-term climate scenario analysis. Additionally, it urges the government to impose express environmental duties and transparency requirements on the Society of Lloyd's to manage the climate impact of the Lloyd's market.

The submission argues that the current pesticide regulatory framework in Canada is inadequate, citing historical failures to prevent unacceptable risks and a reliance on risk assessment over hazard prevention. The authors advocate for a 'planetary health' approach that integrates climate change, biodiversity, and environmental justice into pesticide regulation. They propose 22 detailed recommendations across four areas: lifecycle approach to business practices, improved risk assessment for vulnerable populations, increased transparency in decision-making, and a more rigorous application of real-world data and Maximum Residue Levels (MRLs). Key goals include a 50% reduction in pesticide use by 2030 and the adoption of the precautionary principle.

The document argues that the EPA's Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities is too tentative and fails to commit to the necessary regulatory changes to protect public health. The authors demand the strengthening of the Lead and Copper Rule, the adoption of health-based lead hazard standards for dust and soil, the phase-out of leaded aviation gasoline, and more rigorous cleanup of Superfund sites. They emphasize that lead exposure disproportionately affects communities of color and low-wealth populations, constituting a significant environmental injustice. The coalition calls for a 'whole of government' approach involving the FDA, HUD, and CDC to address lead in food, housing, and pediatric testing.

ClientEarth supports the FCA's proposed SDR and labelling framework in principle but warns that without strict criteria and enforcement, the regime could formalise greenwashing. The organization advocates for the adoption of 'double materiality' in disclosures, the removal of the 'Responsible' label, and the refinement of the 'Sustainable-Transition' label to avoid confusion with climate-specific terminology. It further calls for mandatory sustainability impact metrics and a clear enforcement roadmap to ensure accountability for fund managers.

ClientEarth argues that UK auditors are systemically failing to apply existing accounting and audit standards to climate-related financial risks. Citing the FRC's own 2020 Climate Thematic Review and a report by Carbon Tracker and the Carbon Accounting Project, the letter claims that auditors frequently ignore climate-sensitive assumptions and fail to ensure financial statements are Paris-aligned. ClientEarth calls on the FRC to move beyond monitoring and take meaningful enforcement action, including public investigations into the 'big four' firms (EY, Deloitte, KPMG, and PwC) and stricter oversight of Recognised Supervisory Bodies (RSBs).