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Assessing safeguards for hydrogen sustainability in the H2Global mechanism
The H2Global mechanism lacks minimum sustainability standards, leaving the ambition of future tenders to individual funders. While the BMWK pilot tender aligns with EU regulations on renewable electricity additionality and correlation, it fails to incentivise surplus electricity sharing for local energy access. Water and land use safeguards are insufficient, as they overlook competing local demands for resources and may miss locally significant sites. Additionally, local value creation measures are limited by an export-focused design and unclear guidelines, reducing the potential for sustainable economic impact in producing countries.
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Document type: Research paper
Stellen die Klimaschutzverträge die Nachhaltigkeit von Wasserstoff sicher
The study evaluates Germany's Carbon Contracts for Difference (KSV) and finds that while the program aims to support industrial decarbonization, it may indirectly subsidize 'low-carbon' (fossil) hydrogen. The authors warn against proposed changes to funding guidelines that would remove emission reduction criteria, which would diminish the competitive advantage of green hydrogen. The report also highlights gaps in accounting for transport emissions and the need for a holistic sustainability standard for imported hydrogen to ensure environmental and social safeguards in exporting nations.
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Document type: Research paper
Competition and Climate Policy in the Steel Transition
The research examines how green industrial policies and subsidies affect the cost of low-carbon steel production in the US and EU, concluding that subsidies have a more significant impact on cost reduction than renewable energy costs, which creates a tension between maintaining a level playing field and accelerating climate action.
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Document type: Research paper
Letter: Brussels should resist US calls to roll back green agenda
The We Mean Business Coalition urges the EU to distinguish between simplifying regulatory implementation and rolling back core green legislation, arguing that deregulation would penalise sustainable companies and harm long-term economic stability.
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Document type: Statement
Fossil Fuel Subsidy Reform in Aviation and Shipping
The briefing outlines how international agreements and industry pressure maintain fossil fuel subsidies in aviation and shipping, leading to higher emissions and market distortions. It recommends that countries tax domestic aviation and shipping fuels, reform legal barriers like the Energy Taxation Directive and air service agreements, and advocate for stringent international emissions levies through the ICAO and IMO, specifically suggesting a shipping levy exceeding USD 100 per tonne of CO2.
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Document type: Briefing
AI cannot replace XBRL—but it can reduce the tagging burden and improve reporting quality
The We Mean Business Coalition advocates for the retention of XBRL (eXtensible Business Reporting Language) tagging for financial and non-financial reports, opposing proposals by the European Commission to simplify regulation by removing these requirements. The authors argue that while AI can automate tagging, detect errors, and improve data extraction, it cannot replace XBRL because AI operates probabilistically and lacks the standardization, regulatory compliance, and data integrity required for reliable analysis. The document emphasizes that relying solely on AI-extracted data from PDFs risks inaccuracies in KPIs and figures, which could distort investor analyses and market trust. It concludes that AI should be leveraged to modernize and accelerate the tagging process, but the rule-based structure of XBRL and the associated assurance process by auditors remain essential for traceable and explainable reporting.
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Document type: Statement
Concerns about the inadequate consultation process on the Omnibus Simplification Package
ClientEarth and a coalition of civil society organizations argue that the European Commission's 'Omnibus Simplification Package' is being developed through an opaque, non-inclusive process that violates EU democratic principles and the Commission's own Better Regulation Guidelines. The authors contend that the Commission is facilitating 'regulatory capture' by prioritizing private meetings with industry actors over broad public consultation, potentially undermining the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD). They demand a comprehensive impact assessment and a public consultation involving all relevant stakeholders before any legislative proposal is presented.
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Document type: Statement
Building Future-Proof CO2 Transport Infrastructure in Europe
The report outlines the necessity of a Europe-wide CO2 transport network, estimating a need for 15,000 to 19,000 km of infrastructure by 2050 to move 250 million tonnes of CO2 annually. It argues that because CO2 networks often function as 'natural monopolies', EU-level regulation is required to prevent monopoly pricing and ensure non-discriminatory third-party access. The document recommends inter-temporal cost allocation mechanisms—similar to those used for hydrogen—to avoid 'first mover disadvantage' where early users bear disproportionate costs for oversized infrastructure. It also addresses 'cross-chain' financial risks and the need for harmonised CO2 purity standards to ensure network interoperability and safety.
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Document type: Report
Restructuring Innovation for the Zero-Carbon Climate
The report argues that achieving net-zero emissions requires a broad portfolio of zero-carbon technologies beyond wind and solar, including nuclear fission, fusion, and carbon capture. It introduces an Innovation Technology Framework based on the 'S curve' of innovation, which identifies critical development stages—R&D, early output, and commercialization—leading to 'market take-off.' The framework emphasizes four 'levers of success': lowering costs, speeding project deployment, easing access to financing, and removing ecosystem barriers. The authors advocate for a coordinated industrial policy that provides sustained public financial support until technologies reach the take-off point, typically defined as 1%-2.5% of global energy demand.
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Document type: Report
Dairytales
The report argues that Arla Foods employs 'smokescreens' to hide its significant methane footprint and derail climate legislation. It highlights a gap between Arla's net-zero pledges and its actual practices, noting that the company prioritizes intensity-based targets for Scope 3 emissions rather than absolute reductions. The document details Arla's reliance on biogas as a 'silver bullet' solution, which the authors claim incentivizes industrialization and larger herd sizes over sustainable grazing. Furthermore, it documents Arla's direct and indirect lobbying in the EU to exclude agriculture from the Methane Strategy and block plant-based alternatives in school programs. The report also examines legal challenges in Sweden, Denmark, and the Netherlands regarding Arla's 'carbon neutral' marketing claims, which courts found to be misleading.
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Document type: Report
European Oceans Pact Call for Evidence
ClientEarth urges the European Commission to use the European Oceans Pact to move beyond 'paper parks' and policy silos. The organization calls for a systemic approach to enforcement of the Common Fisheries Policy and Habitats Directive, the creation of an EU Ocean Fund to replace the EMFAF, and the phasing out of fossil fuel subsidies in the maritime sector. It advocates for legally binding targets to protect 30% of EU seas by 2030 and a ban on destructive activities like bottom trawling in all Marine Protected Areas.
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Document type: Statement
Renewable Energy for Nature and People
The document outlines a framework for EU Member States to accelerate renewable energy deployment through Renewables Acceleration Areas (RAAs) without compromising biodiversity or public participation. It emphasizes that RAAs must be designated in areas with no expected significant environmental impact, requiring robust Strategic Environmental Assessments (SEAs) and Appropriate Assessments (AAs). The guide argues that the presumption of 'overriding public interest' for renewable projects is rebuttable and must not bypass strict environmental safeguards. It further details the necessity of meaningful public consultation and effective access to justice at both the planning and permitting stages to ensure legal certainty and environmental protection.
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Document type: Guide
Climate-Aligned Investments and Policy Nexus in Indonesia
The report identifies a substantial investment gap of approximately USD 146.4 billion to meet Indonesia's 2030 Enhanced Nationally Determined Contribution (ENDC) targets. While the government budget provides about one-third of the necessary funding, private financial institutions' contributions remain low, representing only 3% of their total investments. Key barriers include contradictory policies, such as fossil fuel subsidies outweighing climate spending, and a financing mismatch where commercial banks rely on short-term deposits for long-term, capital-intensive climate projects. The report recommends harmonizing sustainable finance policies through the Indonesia Taxonomy for Sustainable Finance (TKBI), enabling alternative instruments like sustainability-linked loans and carbon finance, and enhancing transparency via IFRS S1 and S2 disclosure standards.
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Document type: Report
How the EU carbon market can accelerate decarbonisation by making polluters pay
The report argues that the EU ETS continues to reward heavy polluters through free allowances, which in 2023 alone amounted to approximately 40 billion euros. It highlights that sectors like steel, cement, and chemicals often receive more allowances than they emit, reducing the incentive for decarbonisation. The authors critique the Innovation Fund for over-financing carbon capture technologies (CCS/CCU) rather than scalable zero-emission technologies. To accelerate the transition, the report recommends phasing out free allowances by 2030, fully implementing the Carbon Border Adjustment Mechanism (CBAM), and reforming the Innovation Fund to prioritise material savings and renewable energy solutions.
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Document type: Report
LEVERAGING MONETARY POLICY TO SUPPORT THE TRANSITIONAL NEEDS OF SOUTH AFRICAN WORKERS
The document critiques the Just Energy Transition Partnership (JETP) for focusing on electricity infrastructure over economic diversification and worker needs. It argues that the South African Reserve Bank's (SARB) current inflation-targeting framework and operational independence hinder developmental goals. The author proposes a shift toward 'promotional' central banking, utilizing underexploited liquidity in the banking and retirement sectors—estimated at R52.41bn from banks and potentially R600bn from retirement funds via offshore limit reductions. Key recommendations include reforming the South African Green Finance Taxonomy (SAGFT), implementing mandatory climate risk disclosures, and using credit allocation tools such as targeted refinancing operations, green-differentiated capital requirements, and state investment banks.
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Document type: Research paper
LEVERAGING MONETARY POLICY TO SUPPORT THE TRANSITIONAL NEEDS OF SOUTH AFRICAN WORKERS
The document examines how South Africa's current growth model and monetary governance reinforce a capital-intensive economy and inequality. It identifies significant unexploited liquidity in the banking and retirement sectors and proposes reforms to the South African Green Finance Taxonomy (SAGFT), the adoption of corporate transition plans, and the use of direct and indirect credit allocation tools to fund a just transition for workers.
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Document type: Policy brief
Reforming Environmentally Harmful Subsidies
The document argues that environmentally harmful subsidies (EHS) exceed USD 2 trillion annually, creating perverse incentives that drive biodiversity loss and climate change. It proposes a theory of change based on the 'Multiple Streams and Policy Windows Framework'—defining the problem, identifying solutions, and creating political support—to catalyze reform. The playbook outlines 25 specific opportunities for philanthropic engagement, ranging from independent national assessments and technical support for Global South governments to the creation of 'first-mover clubs' of governments. It emphasizes that transparency alone is insufficient and that durable reform requires the co-development of repurposing strategies to support vulnerable groups and businesses transitioning away from harmful subsidies.
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Document type: Guide
Reforming Environmentally Harmful Subsidies
The document contains technical appendices for a report on reforming environmentally harmful subsidies (EHS). It introduces a 'Fiscal Pressure' indicator to identify countries where high debt and deficits create strong incentives for subsidy reform, and provides a stakeholder analysis mapping the influence and attitudes of businesses, governments, consumers, and civil society toward EHS reform.
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Document type: Report
Fossil Fuel Subsidy Reform in Aviation and Shipping
The document analyzes how international agreements, regional legislation, and industry competition hinder the removal of fossil fuel subsidies in aviation and shipping. It argues that while fuel taxation is often restricted by bilateral agreements or regional directives like the EU's Energy Taxation Directive, emissions levies through the ICAO and IMO offer viable pathways to reduce greenhouse gas emissions and fund the transition to sustainable fuels.
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Document type: Briefing
The State of BCAs 2025
The report examines the implementation of the EU and UK Carbon Border Adjustment Mechanisms (CBAMs) and the preliminary findings of Australia's Carbon Leakage Review. It highlights the shift from free allocation of emissions permits to border adjustments to prevent carbon leakage, where emissions reductions in one country are offset by increases elsewhere. The EU CBAM is set for full implementation by 2026, and the UK CBAM by 2027. Australia is considering a BCA as a 'robust underpinning' to its Safeguard Mechanism. The document also analyzes WTO discussions from 2020 to 2024, noting a transition from general concerns about protectionism and WTO compliance toward specific discussions on cooperation and interoperability.
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Document type: Report