The Sillion Briefing 31.10.2025
A fortnightly digest for corporate sustainability & communications leaders
In this edition...
UK carbon plan refreshed
UK government plans 400k green jobs
IMO delays climate package for shipping
FCA to regulate ESG ratings
England to relax some environmental permits
MEPs reject Omnibus I mandate
Exxon challenges California climate laws
UK Sector Transition Plans launched
NZAM drops portfolio‑wide targets
UNEP: adaptation finance gap widens
Tony Blair Institute urges ‘Cheaper Power 2030’
Glass Lewis retires house policy
UK publishes refreshed Carbon Budget & Growth Delivery Plan
The UK government published a 238-page update to its climate strategy, re-branded as a Carbon Budget & Growth Delivery Plan. Setting out how it intends to meet Carbon Budgets 4-6 (to 2037), the refresh arrives against a legal deadline to lay an updated plan before Parliament by 29 October 2025. Early summaries have emphasised power decarbonisation, planning and network acceleration, and heat and buildings (including a bigger role for energy efficiency and electrification). Reaction from green business groups welcomed the consolidation and investment signal, but questioned delivery risk and policy detail, particularly in hard-to-abate sectors. Scrutiny from Parliament and the Climate Change Committee will shape how much of this turns into bankable policy for 2026-27.
Source: GOV.UK
Why this matters
UK corporates finally have a single reference plan after a year of piecemeal policy moves. Expect investors and ratings agencies to test company transition plans against the eventual policy baseline, especially on electricity demand growth, grid connection timelines, and building heat.
UK unveils national Clean Energy Jobs Plan: ‘400,000 extra jobs by 2030’
The government published the first national plan to recruit and train workers for the clean energy transition, projecting up to 400,000 additional jobs by 2030. The plan identifies 31 priority occupations (e.g., plumbers, electricians, welders), creates five Technical Excellence Colleges, and extends the energy skills passport to support oil & gas workers moving into offshore wind and, in time, nuclear and grid roles. Figures are government projections, not net employment guarantees.
Source: GOV.UK
Why this matters
For developers and supply chain firms, skill gaps impact delivery timelines and capex efficiency. A pipeline of trained labour is also material for FID decisions and OEM siting choices.
Global shipping CO₂ levy delayed by US/Saudi
An extraordinary MEPC session in London voted 57-49 to delay adoption of a Net Zero Framework that included a carbon levy and fuel GHG intensity standard, pushing expected entry into force beyond 2028. The delay frustrates shipowners seeking certainty on requirements for their future vessels. The vote followed a strong US push with explicit threats of retaliation
Source: Reuters
Why this matters:
The delay removes near-term clarity for fuel switch investment decisions (e-fuels, methanol, ammonia) and could widen the policy gap between EU/UK regional regimes and global rules - raising leakage and competitiveness questions. It also showcases how geopolitical pressure can derail sector wide climate instruments.
UK to regulate ESG ratings providers under FCA
Legislation has passed to bring ESG ratings providers within the FCA’s regulatory perimeter. The FCA welcomed the move and will develop detailed rules; HMT’s earlier consultation response set the direction of travel. The aim is to boost transparency on methodologies and manage conflicts of interest, aligning with IOSCO recommendations. Scope includes overseas providers offering ratings to UK clients.
Source: FCA
Why this matters
Users should see more consistent inputs as ratings providers face governance, transparency and conflicts management requirements. As with credit ratings markets, commercial incentives and potential conflicts will still require active oversight by users and regulators.
UK government announces ‘common sense’ shake up of environmental permitting
DEFRA and the Environment Agency outlined reforms to speed permitting for housing and infrastructure by streamlining assessments and exemptions for lower risk activities in England. Critics warn on nature risk; supporters cite growth and grid needs.
Source: GOV.UK
Why this matters
Faster permits could unblock clean energy and grid projects - but expect legal and reputational scrutiny where nature safeguards are perceived to be diluted or shifted from project by project mitigation.
EU Parliament knocks back “Omnibus I” simplification mandate
On 22 October, the European Parliament rejected the Committee on Legal Affairs (JURI)’s mandate on the Commission’s Omnibus I simplification proposal (amending CSRD and CSDDD), sending the file back for amendments but with an end 2025 wrap-up still the stated aim. Centre ground divisions remain over how far to pare back scope.
Source: EU Parliament
Why this matters
For EU/UK groups in CSRD scope (including UK subsidiaries with EU listings/size thresholds), the rejection prolongs uncertainty - the direction of travel on thresholds, exemptions, and cadence remains contested.
Exxon sues California over climate disclosure laws (SB 253 & SB 261)
Exxon Mobil filed suit in a US District Court to block California’s emissions (SB 253) and climate risk (SB 261) disclosure laws, arguing compelled speech, conflicts with federal securities law, and other constitutional grounds. The case follows earlier business group challenges that failed to secure a preliminary injunction.
Source: Reuters
Why this matters
A ruling could reshape the emerging US disclosure patchwork: many multistate filers are building compliance programs for California in parallel with SEC litigation. A plaintiff win could dilute scope 3 and risk reporting momentum beyond California.
UK Net Zero Council launches Sector Transition Plans
The Net Zero Council (a Government-industry partnership to liaise between the two and advise the former), along with the Transition Finance Council, launched Sector Transition Plan guidance and a Finance Playbook, aligned with the UK’s TPT work. These are non statutory tools to help mobilise investment and coordinate sectoral roadmaps.
Source: BusinessGreen
Why this matters
Sector level clarity is what lenders and asset owners repeatedly ask for. Credible STPs can de-risk pipelines (power, heat, industry), inform corporate transition plans, and improve the investability of high-emitting value chains.
NZAM relaxes target requirement ahead of 2026 reboot
The Net Zero Asset Managers (NZAM) initiative, which paused operations after major US exits, has circulated a revised commitment that removes the obligation to set portfolio-wide net zero target by 2050 and interim targets, shifting focus to client-centric climate risk support and stewardship. Members will be asked to opt in to an updated statement.
Source: Edie
Why this matters
This again weakens the convergence signal asset owners/managers had been sending to issuers. Companies should expect more heterogeneity in investor expectations, even as many European managers stick with targets. Further US retrenchment (e.g., State Street’s US arm) underscores ongoing political/legal headwinds.
UNEP highlights adaptation finance gap
UNEP’s Adaptation Gap Report 2025: Running on Empty estimates developing country adaptation needs at roughly $310–$365bn per year by the mid 2030s, far above present flows estimated at $26-$40bn.
Source: UNEP
Why this matters
In line with a broader turn towards adaptation, boards could anticipate more investor and lender scrutiny of physical‑risk exposure and adaptation capex across the supply chain.
Green policy row: Tony Blair Institute urges a reset of ‘Clean Power 2030’
The Tony Blair Institute (TBI) published Cheaper Power 2030, Net Zero 2050, arguing the government should reframe or relax the 2030 clean power mission to prioritise affordability and system flexibility. Commentators criticised the recommendation as undermining investor confidence and long-term cost reduction.
Source: TBI
Why this matters
For energy and heavy user corporates, policy stability is the signal that unlocks multi-year capex, and keeps cost of capital low. A public debate over the 2030 mission - were it to arise - would introduce uncertainty into power price and connections forecasts, affecting a slew of other investment and development factors.
Glass Lewis to end uniform proxy voting stances from 2027 amid EU/US ESG divergence
Proxy adviser Glass Lewis will retire its “benchmark” (house) policy in 2027, moving clients to customised voting frameworks that reflect varying investor priorities and regional norms. The firm cited widening EU/US divergence on fiduciary duty and ESG, and ongoing political scrutiny in parts of the US market. This mirrors a broader market trend toward client-specific voting policies, “pass through” or preference driven voting, and more granular stewardship.
Source: Financial Times
Why this matters
For UK, EU, and US issuers, this raises variability in voting outcomes and reduces the signalling power of a single proxy house view. Expect more investor specific engagement asks, and more split outcomes on E&S proposals.
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