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ClientEarth and the European Environmental Bureau (EEB) have expressed serious concerns regarding the European Commission's revision of the State aid Guidelines on climate, environmental protection and energy (CEEAG). They argue that the Commission is favoring energy intensive users (EIUs) by potentially expanding aid eligibility to companies only 'at risk' of carbon leakage, rather than those at 'significant risk'. The authors contend that the risk of carbon leakage remains 'unproven' and that maintaining reductions in electricity levies for EIUs contradicts the European Green Deal and the Polluter Pays Principle. They advocate for 'Option E2' (the ETS list), which would restrict aid to 14 eligible sectors, resulting in an estimated 89% annual budget reduction and 'much lower competition distortions'. Additionally, the letter criticizes the Commission's governance, alleging a breach of EU jurisprudence by failing to make impact assessments publicly accessible before adopting proposals.

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).

The document is a formal statement from a coalition of 150 NGOs advocating for the EU Nature Restoration Law to adopt specific, measurable targets rather than percentages of degraded areas. The signatories argue that current Member State reporting is insufficient and propose a headline target to restore at least 15% of EU land, sea, and river length by 2030.

ClientEarth criticizes the Society of Lloyd’s ESG Guidance for being non-binding and lacking transparency, short-term targets, and a fossil fuel phase-out plan. The letter asserts that the Guidance represents a retreat from previous commitments and risks legal breaches regarding climate risk management and public disclosure.

ClientEarth has issued a formal letter to Deloitte alleging that the firm is failing to demonstrate how it incorporates material climate risks into its audits of listed companies. The document asserts that existing standards from the IASB, IAASB, and FASB already require the consideration of climate-related matters. Referencing a report by Carbon Tracker and the Carbon Accounting Project, ClientEarth claims that Deloitte and other auditors are habitually failing to provide evidence of climate risk assessment, creating an information gap for investors and risking legal liability in jurisdictions such as the UK and US. The letter calls on Deloitte to review its audit practices, ensure consistency between financial statements and narrative climate commitments, and adopt Paris-aligned accounting assumptions.

ClientEarth asserts that KPMG and other auditors are failing to incorporate material climate-related financial risks into company audits, despite clear guidance from standard-setters like the IFRS Foundation and IAASB. Referencing a Carbon Tracker report, the letter highlights a systemic lack of transparency regarding climate-sensitive assumptions and a failure to align accounts with the Paris Agreement. ClientEarth warns that this creates a material information gap for investors and exposes KPMG to regulatory sanctions and legal liability in the UK and US.

ClientEarth asserts that EY and other auditors are failing to incorporate material climate-related financial risks into company audits, despite clear guidance from standard-setters like the IFRS Foundation and IAASB. Referencing a Carbon Tracker report, the letter highlights a systemic lack of transparency regarding climate-sensitive assumptions in financial statements. ClientEarth warns EY of potential legal and regulatory liabilities in the UK and US and calls for a comprehensive review of its audit practices for carbon-intensive firms.

ClientEarth has issued a formal letter to PwC alleging systemic failures in the audit of climate-related financial risks. The document asserts that existing IFRS, US GAAP, and IAASB standards already require the consideration of material climate risks, yet a report by Carbon Tracker indicates that PwC and other auditors frequently fail to demonstrate this scrutiny. ClientEarth warns that such failures create an information gap for investors and expose PwC to regulatory sanctions, shareholder claims, and potential criminal liability. The letter calls for a comprehensive review of PwC's audit practices for carbon-intensive companies and a commitment to using Paris-aligned accounting assumptions.

ClientEarth argues that current Trade and Sustainable Development (TSD) chapters in EU FTAs are often insufficient and lack effective enforcement. The document proposes a 'blueprint' to integrate core environmental principles into the general chapters of agreements, make ratification conditional on multilateral environmental agreements (MEAs), and introduce a robust system of sanctions for non-compliance. It specifically advocates for the systematic inclusion of the precautionary principle and the creation of reciprocal complaint mechanisms for civil society. The briefing also details specific legal obligations the EU should seek regarding climate (1.5°C limit), biodiversity (30% protected areas), deforestation-free products, and the elimination of harmful fisheries subsidies.

The briefing argues that the Komstroy ruling effectively bars investor-State dispute settlement (ISDS) between EU investors and Member States under the ECT, creating systematic obstacles to the recognition and enforcement of such awards within the EU. It highlights that EU Member States are now obliged to challenge these awards and that EU State aid rules may further prevent the payment of compensation. The document specifically applies these legal hurdles to pending cases brought by RWE and Uniper against the Netherlands regarding its coal phase-out policy.

ClientEarth argues for the full alignment of EU air quality standards with the 2021 World Health Organization (WHO) guidelines through legally binding limit values. The document proposes strengthening the legislative framework by introducing an independent Scientific Advisory Board on Healthy Air, enhancing the requirements for air quality plans, and expanding monitoring to include Black Carbon and Ultrafine Particles. It further calls for explicit access to justice provisions, harmonised compensation for health damages, and the introduction of administrative penalties for public authorities that fail to comply with air quality standards.

The briefing analyzes the proposed EU law on deforestation-free products, which aims to replace the EU Timber Regulation (EUTR). It highlights improvements such as the expansion of covered commodities to include cattle, cocoa, coffee, oil palm, and soya, and the introduction of a 'deforestation-free' criterion alongside legality requirements. The document notes strengthened due diligence for large traders, mandatory geo-localisation coordinates for traceability, and more rigorous compliance check requirements for Member States. However, it warns of definitional ambiguities regarding 'forest' and 'deforestation' and criticizes the failure to include criminal liability for serious violations.

The European Commission's proposed regulation aims to minimize the EU's impact on global forests by establishing a 'deforestation-free' standard for cattle, cocoa, coffee, oil palm, soya, and wood. The framework relies on mandatory supply chain due diligence, requiring full traceability to the point of production via geolocation coordinates. While it improves upon the EU Timber Regulation by introducing objective science-based standards and stronger penalties (up to 4% of annual turnover), it contains a 'simplified due diligence' loophole for low-risk countries. ClientEarth identifies critical gaps compared to the European Parliament's 2020 INL Report, specifically the lack of mandatory human rights protections, the exclusion of non-forest ecosystems like peatlands, the omission of the financial sector, and the absence of civil liability for victims of deforestation.

The CEEAG guidelines, effective from January 2022, streamline public financial support for decarbonisation, renewables, and nature restoration while introducing new categories for clean mobility and coal phase-out. While they promote technology-neutral competitive tenders, the document highlights concerns regarding continued support for fossil gas, the lack of a clear definition for 'low-carbon hydrogen', and the limited ambition of energy efficiency commitments for energy-intensive users.

The report by ClientEarth and the EEB uses ECHA data to project that intentionally added microplastics will continue to increase in the environment through 2030. It highlights that a one-year delay in the restriction's entry into force would increase total emissions by approximately 40,000 tonnes by 2030. The analysis identifies sports pitch infill as the largest source of pollution and criticizes the lack of data for sectors such as construction and food additives.

ClientEarth criticizes the ECB's 2021 Climate Roadmap as being too vague and slow to address the carbon bias in its Corporate Sector Purchase Programme (CSPP) and Pandemic Emergency Purchase Programme (PEPP). The organization argues that the ECB continues to subsidize greenhouse gas-intensive companies and fails to meet its legal obligations under EU treaties. ClientEarth calls for the immediate exclusion of bonds from companies involved in coal, unconventional oil and gas, and new fossil fuel exploration, as well as the requirement for issuers to adopt credible Paris-aligned transition strategies by January 2023.

ClientEarth argues that the Society of Lloyd’s is risking 'greenwash' by making public net-zero commitments while keeping the specific guidance issued to managing agents private. The letter asserts that without transparency, it is impossible to verify if Lloyd's is following a science-based pathway or maintaining its previous 'Fuel Targets' to exit coal, tar sands, and Arctic oil. ClientEarth warns that misleading statements could breach the legal and regulatory duties of the Society and its Council members under FCA and PRA rules.

The briefing argues that the EMFAF (2021-2027) is outdated and fails to address the climate and biodiversity crises. It urges EU Member States to use their discretionary power to shift funding away from industrial fleets and harmful subsidies toward small-scale fisheries and marine restoration. The author proposes a 'FAIR' framework—Fair, Ambitious, Innovative, and Revitalising—and lists 15 specific recommendations, including allocating at least 25% of national budgets to marine environment conservation and prioritizing funding for artisanal fishers to enhance European strategic autonomy and carbon sequestration.

ClientEarth argues that the recast Energy Efficiency Directive (EED) must remove support for fossil-fuel technologies, including natural gas and high-efficiency cogeneration, to avoid carbon lock-in. The organization recommends raising the 2030 EU energy efficiency target to at least 45% and making national contributions legally binding. It further advocates for the 'Energy Efficiency First' (EE1st) principle to be extended to all planning and investment decisions, not just 'major' ones, and calls for a more robust role for energy communities in achieving energy savings.

ClientEarth evaluates the Environment Act 2021, noting that as a framework law, its success depends on future targets and rules. The organization criticizes the Act for failing to align air quality targets with WHO guidelines and for creating a loophole in deforestation laws by only restricting commodities produced illegally under local laws, which may fail to protect the Amazon rainforest.