Introduction: The NED perspective
by David Carlin, Chapter Zero Fellow
"Parts of 2025 seemed to indicate that sustainability was in eclipse. However, around the world, and especially in the UK and EU, firms and regulators have kept up efforts to accelerate the transition. The US-Iran conflict has created unprecedented challenges in energy markets and global supply chains. Many of these impacts including inflation and energy shortages will only intensify in the months ahead. The nature of the conflict demonstrates that the case for renewables and sustainable energy systems has never been stronger. Amid geopolitical and economic shocks, those that have been building self-sufficient, low-carbon energy infrastructure have a real advantage.
Beyond the immediate energy challenges, regulations continue to show that policymakers recognize the destabilizing effects of climate change.
This briefing is incredibly timely for NEDs. Board members should consider the intersection of policy and regulation with the volatile energy and economic conditions that prevail – doing so will enable them to help steer their firms successfully through a time of change."
Summary Briefing
This Summary Briefing highlights the essential need-to-knows for NEDs in terms of emerging policy and regulatory developments announced from the start of January 2026 to May 2026, offers suggested prompts for boardroom discussions, and includes some upcoming key events and UK Government consultations regarding climate policy that may be useful for boards to be aware of.
The full briefing below offers more detail on each of the key policy areas relevant for boardrooms in regard to the climate agenda.
Key takeaways for Non-Executive Directors
- Updates from the King’s Speech: During the King’s speech, King Charles declared that “an increasingly dangerous and volatile world threatens the United Kingdom, with the conflict in the Middle East only the most recent example. Every element of the nation’s energy, defence and economic security will be tested.” 37 Government bills were announced including the Energy Independence Bill; Steel Industry (Nationalisation) Bill; Clean Water Bill; Railways and Passenger Benefits Bill; European Partnership Bill; Regulating for Growth Bill; and Competition Reform Bill. One notable absence was the mention of North Sea Oil amid commitments to “tackle change and end poverty.”
- National energy security concerns bring the pace of the UK’s clean energy transition into focus: Geopolitical instability and persistent energy market volatility have increased attention on the UK’s 2030 Clean Power mission. The National Energy Systems Operator (NESO) published its annual Summer Outlook in April, in which it claims, “despite the geopolitical backdrop, we remain confident in the security and resilience of electricity supply this summer”, while still cautioning that the US-Iran conflict is expected to raise energy prices due to the UK’s ongoing dependence on gas. Growing debates around the trade-offs between ‘cheap’ and ‘clean’ power highlight how, “when gas prices rise dramatically as in recent weeks, electricity bills tend to rise with them – even if much of the power itself is renewables that are cheap to produce.”
- The Commons Energy Security and Net Zero Committee convened in February to examine how expanding domestic renewable energy could reduce exposure to supply shocks, protect critical infrastructure, and limit vulnerability amid ongoing trade and energy conflicts. There have been positive signals of domestic capacity gains, with January’s seventh Contracts for Difference (CfD) allocation round (AR7) delivering record levels of clean energy capacity in “Europe’s biggest ever offshore wind auction”, showcasing the scale and momentum of the UK’s deployment pipeline despite challenging market conditions. The Department for Energy Security and Net Zero (DESNZ) has committed to publishing an Energy Resilience Strategy in 2026 and to establish an Energy Security and Resilience Taskforce to combat “higher borrowing rates and tighter supply chains”.
- The evolving relationship between energy security, national resilience and decarbonisation policy may affect businesses’ long-term investment decisions, procurement strategies, and exposure to energy price volatility in the short to medium term, and boards should prioritise mapping these risks. There is important momentum to build on, with April analysis from Ember finding that globally, renewable energy overtook coal as the world’s largest source of electricity in 2025.
- UK SRS set out framework for sustainability disclosure: The UK Sustainability Reporting Standards (UK SRS) were published on 25 February, setting out the UK’s new framework for sustainability disclosures. The standards, which align with the IFRS Sustainability Disclosure Standards, comprise of two components: UK SRS S1, which includes the general framework for applying UK SRS, and UK SRS S2, which sets out requirements on climate-related risks and opportunities. Currently available for voluntary use, mandatory reporting is anticipated from January 2027 for in-scope listed companies under new UK Listing Rules. The FCA consulted on replacing its current TCFD-aligned listing rules up until March 2026 and is expected to publish final rules in Autumn 2026. Early board engagement with UK SRS governance, data systems and internal processes could be key to meeting forthcoming disclosure requirements and maintaining investor confidence in regulatory alignment.
- Green economy identified as UK’s fastest growing sector following continued investment: An update on the UK’s Modern Industrial Strategy was published in January, highlighting how around £79 billion in investments into eight high-growth sectors, including clean energy industries and advanced manufacturing, was made in the final quarter of 2025. Building on this momentum, the Government published the Industrial Strategy Prospectus in March, providing an overview of the 10-year plan to “significantly increase business investment” in these high-growth sectors by fostering “enduring partnership”. Alongside this, the UK Steel Strategy was launched in March setting out a vision for a revitalised steel sector consisting of “productive and profitable green steel producers”, building on the “UK’s natural advantages” including its abundance of scrap and grid decarbonisation progress. On 11 May Prime Minister Sir Keir Starmer stated legislation would be brought forward to take “full ownership of British Steel” and was confirmed by the King’s announcement of the Steel Industry (Nationalisation) Bill during his national address. Taken together, these industrial policy developments signal a continued investment in business leadership and capital allocation, and boards may take advantage of clearer sectoral roadmaps and blended finance mechanisms by creating investable opportunities whilst preparing for heightened expectations around corporate alignment with industrial transition pathways.
- Biodiversity warnings push for urgent industry-government action on nature: In January, the UK government published a Nature Security Assessment, which calls for accelerated domestic action after identifying how the decline of six ecosystems of strategic importance could drive cascading global impacts. The urgency is underscored by data from the February Environmental Protections and Biodiversity Trends research briefing, finding that most UK-wide biodiversity indicators have deteriorated or stayed the same since the last update in December 2025. A March report from the UK Centre for Ecology & Hydrology (UKCEH) warns that there is a closing 20-year window in which decisions on climate and land use will determine the fate of dozens of plant and animals species in the UK, with 2050 representing a point of no return. Also in March, the UK government published its response to a 2025 call for evidence on expanding the role of the private sector in nature recovery, in which it asserts that business investment remains key to environmental improvement, considering that “despite the good progress which has been made, we still need to go further in enabling economic sectors which impact or depend upon nature and the services nature provides to invest in reducing the environmental harms of their operations and growing our shared natural capital.” The elevation of biodiversity loss to a matter of national security sharpens the case for businesses’ integration of nature-related risks into strategic planning and disclosure frameworks.
- New land-use framework outlines direction for "more efficient land use" amidst competing national development priorities: England’s first-ever Land Use Framework (LUF) was published by on 18 March, setting out a plan for managing the country’s finite land to ensure long-term resilience, with a commitment to delivering new homes, nature restoration and clean energy objectives, provided that land is used more efficiently and for multiple benefits. The Framework’s ambition sits against a challenging backdrop, as currently just 7% of England’s land is protected for nature, with just four years to go until the 30by30 deadline. The LUF provides a clearer spatial and policy context for business decisions involving land-intensive assets, supply chains and nature-related dependencies, particularly as the Government plans to establish a dedicated Land Use Unit within the year to oversee implementation of these objectives.
- UK Compute Roadmap: The Department for Science, Innovation and Technology (DSIT) published a revision to the UK Compute Roadmap’s on 23 April, providing updated forecasts of the environmental impacts of AI. New modelling estimates that between 2025 and 2035, the greenhouse gas emissions from AI compute could range from 34 to 123MtCO₂ – which could represent between 9-3.4% of the UK’s total projected emissions over the period. Response to the revised figures finds that carbon emissions from data centres “could be 100 times greater than previously thought […] significantly higher than a forecast published in July 2025”, prompting heightened concern from green groups and MPs on how the UK government’s plans to “build a world-class compute ecosystem” impacts its legally-binding commitment to reach net zero by 2050. This comes as the Government announced the first wave of its £500 million Sovereign AI programme funding to help drive growth.
- UK CBAM consultation: Following a consultation on draft UK carbon border adjustment mechanism (UK CBAM) regulations, which ran until 24 March, the UK government launched a further consultation on additional implementing legislation on 9 April 2026 which closes on 21 May 2026. A policy summary for CBAM is available here.
- PRA deadline: The Prudential Regulation Authority (PRA) has set a 3 June 2026 deadline for UK banks, building societies, PRA-designated investment firms, and insurance and reinsurance firms to review and set out how they intend to meet new climate risk policies outlined in its December 2025 supervisory statement.
- UNFCCC Bonn Climate Change Conference: The United Nations Framework Convention on Climate Change (UNFCCC) will host its annual June Climate Meetings (SB64) from 8-18 June 2026 in Bonn, Germany.
- London Climate Action Week (LCAW) will take place between 20-28 June 2026.
- Seventh Carbon Budget: The UK government is required to set the Seventh Carbon Budget (CB7), the UK’s legally-binding greenhouse gas emissions limit for the period 2038-2042, in law by 30 June 2026.
- Allocation Round 8 of CfD: The UK government has confirmed that the next auction for new clean energy projects, Contracts for Difference (CfD) Allocation Round 8 (AR8), will open in July 2026.
- The UK Climate Change Committee will publish its progress report on UK Adaptation by the end of May 2026. This progress report will consider the latest scientific research on climate change against the measures the UK has taken to ensure infrastructure and system are resilient and adaptable to changing climate conditions. It will provide a thorough assessment and offer recommendations on the progress pathway. Further details will be available on the Climate Change Committee's website: Climate Change Committee.
- ISO Standards release: The International Standards Organization (ISO) is set to release two key standards: The ISO Sustainable Finance - Net Zero Transition Planning for Financial Institutions Standard (ISO 32212) will be launched on 4 June - this Standard will establish a globally aligned framework for how FS firms develop transition plans, with key implications across the sector and into the real economy as FS firms determine their lending and portfolio strategies. Further details of the development of the Standard can be found here. Importantly, ISO is also developing its Net Zero Standard (ISO 14060) which will be open for public consultation later this year. According to materials from the British Standards Institution (BSI): "The ISO net zero standard will provide a universal baseline for what "good looks like" when it comes to taking net zero action as an organization. It tackles the fragmented net zero governance landscape by converging global best practice in one place." Further details can be found here.
- SBTi Corporate Net Zero Standard V2: The Science-Based Targets initiative (SBTi) is currently working on a major update to its Corporate Net Zero Standard. The second public consultation has now closed, and the V2 Standard is expected to release later this year, possibly in the Summer. For boards, particularly those whose firms have adopted SBTi targets or intend to do so, it will be key to ensure reporting teams are engaging with this update and a strategic review is conducted to ensure continued alignment. Further details can be found here.
Full Briefing
Introduction
Our quarterly UK policy briefing aims to highlight the latest developments in UK climate policy relevant to Non-Executive Directors (NEDs). Carrying on from our last briefing, this edition considers policy developments from the start of 2026 through to the end of April.
The first quarter of 2026 has seen a range of climate policy development both internationally and at home. At the World Economic Forum in Davos in January, the relatively limited focus on international climate action was framed primarily through the lens of energy security and industrial policy, reflecting a more fragmented geopolitical backdrop amidst the escalation of the US-Iran conflict. In a 21 April speech, Energy Secretary Ed Miliband drew on the ongoing geopolitical context as evidence that “the era of fossil fuel security is over, and the era of clean energy security must come of age.” A package of measures has been introduced to reduce UK dependence on volatile fossil fuel costs, including an additional £100 million in funding to deliver energy upgrades through the Warm Homes Plan, moving forward renewables auction timelines, and accelerating planning and grid connection reform to enable critical clean energy infrastructure delivery.
In February, the UK government published the long-awaited UK Sustainability Reporting Standards, with UK SRS S1 and SRS S2 providing the UK’s new framework for sustainability disclosures, closely aligned with the ISSB’s global baseline. Chancellor Rachel Reeves delivered the Spring Forecast 2026 speech on 3 March with limited new climate-specific spending measures outlined, but continued signals of commitment to the green transition. Meanwhile, parliamentary and government preparations for the Seventh Carbon Budget (CB7) – which sets the UK’s legally-binding emissions limit for 2038-2042 – have gathered pace ahead of the statutory June 2026 deadline, with the Environmental Audit Committee publishing its report on CB7 in early March. These developments set the tone for what is likely to be a decisive year for UK climate governance, with the decisions taken in the months ahead on carbon budgets, disclosure requirements and clean energy investment poised to shape the trajectory of domestic policy well into the coming decade.
Suggested boardroom discussion prompts
Board discussion prompts
- Does our business strategy or transition plan reflect the latest policy and regulation developments? Have these changes opened up any new opportunities for industry collaboration, investment or funding? Have we fully identified and assessed our policy dependencies in light of these changes? Do we have a policy engagement plan to address and manage these dependencies? Have we audited our trade association positions on these policy changes to ensure they align with our strategic ambitions?
- Are any of the ongoing Government consultations, including on Reformed National Pricing and UK trade, relevant to our net zero activity and transition planning? Should we be capitalising on these opportunities to engage?
- Have we assessed if/how the new UK SRS may impact our reporting and disclosure obligations? What are our current gaps in data quality and coverage, and what investment is needed to close them ahead of mandatory deadlines? What are our governance responsibilities under the SRS requirements?
- Are our scenario analysis capabilities sufficiently robust to support the forward-looking disclosures the standards require? Are our peers and competitors moving to early voluntary adoption of UK SRS, and what are the reputational implications of our own pace of adoption?
- Considering the Chancellor’s Spring Forecast and the Energy Secretary’s suite of energy security measures, do we as a board have sufficient insight into what budgetary assumptions are being made about the impacts of trade and climate policy on our supply chains, costs and growth? How resilient are our plans if these external pressures intensify and/or change?
- Given the divergence in global climate policy directions, how can we ensure our policies and practices both maintain compliance and demonstrate leadership? How confident are we that our leadership team is positioning us to respond proactively to the shifting international policy environment, while still aligning with UK policy drivers that may set us apart?
- Are there opportunities for us to think differently about how we mitigate and manage emissions? Have we considered adaptation fully in our transition planning? Do we have the right information, skills and competencies on the board to help us respond to calls for accelerated climate action?
- Given the AI/Compute roadmap, are we as a board clear on how AI is being used throughout the organisation and what the implications are in terms of energy and other resources (e.g. water)? If relevant to our sector, have we considered the implications for data centre investments?
Relevant policy resources
For NEDs interested in more in-depth research relating to current UK policy trends, there are a range of resources available, including:
- The UK Clean Power Coalition published its first report, The Electric Economy: Creating Consensus, Communicating Change, in February. The report offers insights into how the shift to clean power will impact energy costs, investment decisions and long-term competitiveness which may be relevant to boards. EU-level analysis was shared by the Brunswick Review in April, offering further expert commentary on the significance of electrification in delivering the energy transition.
- Edie, in partnership with Centrica Business Solutions, has released the Business Leaders' Guide to Energy Resilience 2026 which provides actionable tips and advice for businesses on how to improve their energy resilience with a particular emphasis on the importance of board-level intervention.
- OnePointFive has published part 1 of its ‘From Climate Risk to Business Action’ series, outlining business guidance on the foundations of physical and transition climate risks.
- The World Resources Institute (WRI)’s working paper, The Triple Dividend of Building Climate Resilience: Taking Stock, Moving Forward, provides insightful data points on the benefits of climate change adaptation investments.
- In January, the World Economic Forum shared Climate litigation is evolving – and businesses should take notice, outlining insights on key trends in national jurisdictions and litigation risks for companies. This was followed up by the April 2026 briefing, Climate Litigation: From Compliance to Strategic Imperative.
- The Climate Group has published a summary of key policy debates that will define 2026 in its article, What’s shaping climate discourse for governments and policymakers in 2026?, providing a useful timeline for boards. Related research from Mitiga Solutions outlines 12 Climate Risk Predictions That Will Shape 2026.
- Energy Systems Catapult has published its Innovating to Net Zero 2026 report and interactive dashboard, which provides insights on the innovations in flexibility technologies and services needed to unlock opportunities for UK businesses and consumers. Boards can explore the data in more detail on the interactive dashboard.
- Coming out of Davos 2026, the World Economic Forum published a number of resources on business leadership including, What leadership looks like now and in the future; Redefining leadership: Dialogue in a changing world; and its January 2026 report, Next Generation Leadership for a World in Transformation: Driving Dialogue and Action. Also in January, the WEF’s 2026 Global Risks Report was published.
- FTSE Russell released an article Climate Concerns Still Top of Mind for Investors in February which outlines high-level insights on its annual global asset owner survey and latest thinking on sustainable investment adoption.
- Accounting for Sustainability (A4S) has published a case study, Nature as a Source of Long-term Value, which highlights business thinking on engaging investors and rethinking financial instruments for the nature transition agenda.
- A March report from the Universities of Strathclyde and Aberdeen, Stick or twist? Why the UK's net-zero strategy is faltering and may need to change, outlines evidence on current trends in public buy-in to net zero policy, outlining a number of ways messaging and governing can be improved. The report provides helpful public opinion statistics to inform business thinking on communicating the net zero transition.
- An article authored by UK specialists was published in February, calling for a global assessment of avoidable climate change risks, and the potential impact this would have on policymaking. Boards may utilise the debates discussed to inform their discussions on climate risk assessment.
- Insights on business leadership amidst regulatory uncertainty are provided in an April article published in SustainableViews, Self-regulation at speed: how industry can shape better climate policy.
- A report published in Nature communications in January, Climate policy portfolios that accelerate emission reductions, analyses policy instruments across over 40 OECD countries and emerging economies – representing the “most comprehensive climate policy dataset ever assembled.” The report includes exemplar country case studies.
David Carlin
David is a Fellow of Chapter Zero