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12/12/2025
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Offering Direction When Policy Moves Backwards
15/11/2025
Clarity, stability, and practical paths that do not depend on Brussels.
The Omnibus uncertainty, the legal challenges now looming over the European Commission, the 90 per cent cut to CSRD scope, and the wider setbacks emerging from COP30 have created a difficult moment. Educators feel the ground shifting beneath their teaching. SMEs worry that the rules change faster than they can plan. Yet this is exactly where a stable framework becomes most valuable.
The message we can offer is straightforward. The law may move, but the fundamentals of sustainability do not. Education still needs a simple way to teach responsible practice. SMEs still need clarity on what good looks like. Both groups want practical steps they can take today, without waiting for the next Parliament vote.
What We Can Provide Right Now
Reliable structure, stable learning, and action that stands even when the rules change.
We can offer three things with confidence.
1. A stable learning pathway for schools, colleges, and universities.
Students need a clear route into sustainability literacy. We can provide that through tools that teach real-world skills, not shifting regulations. The SDG-based approach remains solid because it is built on global consensus, not political cycles. Teachers can continue to use these resources knowing they will remain relevant.
2. A simple, practical framework SMEs can use for ESG and responsible business.
Instead of waiting for final CSRD wording, SMEs can work from principles that never change. Understanding their impact, improving governance, reducing waste, strengthening fairness, and documenting progress. These are not dependent on thresholds, exemptions, or ESRS revisions. They are good practice in any market and under any law.
3. A clear way to show proof, even when compliance rules are uncertain.
SMEs want to demonstrate progress without drowning in reporting. We can offer straightforward badge pathways, checklists, and short evidence requirements that help them track impact internally. If legislation tightens again, they will already have the structure and materials in place.
The Direction We Offer
Hope that is grounded in work people can start now.
At 169to1®, we are telling Educators and SMEs the same thing. You do not need to wait for Brussels or for leaders in Belém at COP30 to behave. You can take responsibility for your own teaching and business practices today, using simple tools that outlast political cycles. The rules may shift, but clarity, transparency, fairness, and responsible action do not.
This is the hope we offer. Not empty promises, but steady ground.
COP 30: Where We Stand Now
14/11/2025
The implications of falling away from 1.5 °C, and why clarity matters now.
Key Takeaways from COP30 So Far
A clearer picture of where the world stands, and why steady frameworks now matter.
1. A sharp reality check on the 1.5 °C limit
COP30 has accepted that staying below 1.5 °C is becoming far less achievable. Current national plans point towards 2.3–2.5 °C of warming unless action strengthens. The tone has shifted from optimism to course-correction. For 169to1, this reinforces the need for practical systems that help institutions act now rather than wait for perfect policy conditions.
2. Adaptation and resilience are rising in importance
Developing countries may require more than US$300 billion per year by 2035 to cope with storms, floods, fires, and other impacts. Mitigation remains essential, but adaptation is no longer secondary. ESG and SDG frameworks must build resilience indicators into their core design, not as optional additions.
3. Climate finance remains uncertain
The gap between what is promised and what is delivered is widening. There is renewed pressure to use public funds to unlock private investment. Debates around carbon markets continue to complicate planning. For organisations, this confirms that sustainability planning must include financial mobilisation, governance of funds, and transparent mechanisms, not only emissions targets.
4. Forests, land, and indigenous rights at the centre
Hosting COP30 in the Amazon has placed biodiversity, forest protection, and indigenous communities at the heart of discussions. Yet there are tensions, including Brazil’s continued approval of new oil exploration. For 169to1, this underlines the importance of including land-based indicators and rights-based approaches within your Selection and Activation pillars.
5. Geopolitical fragmentation is widening
Major emitters are not participating in full force, which weakens global coordination. Europe is trying to fill the gap, but is also balancing economic and security pressures. This environment demands ESG and SDG systems that can operate across shifting political landscapes. Your accreditation model already fits this need by focusing on local action and verifiable results.
6. Institutions face rising expectations
Organisations are being asked not just what they plan to do, but how and when they will do it. Long-term net-zero pledges are losing credibility without clear near-term steps. Finance, governance, land use, and resilience are becoming essential components of sustainability planning. This aligns directly with your badge-based compliance approach, which emphasises evidence, milestones, and integrity.
THE EU Omnibus Rollback
14/11/2025
What the EU’s rollback of sustainability rules means now, and why preparedness still matters.
A Weakened Framework
The EU has pushed through a political deal that strips back the key sustainability pillars that were meant to anchor the Green Deal. The alliance between the EPP and far-right groups has raised reporting thresholds, delayed technical standards, and removed several accountability mechanisms.
The core changes are clear:
CSRD thresholds jump to 1,750 employees or €450 million turnover, removing about ninety per cent of companies from mandatory sustainability reporting.
Sector-specific ESRS and non-EU company standards are postponed, reducing comparability and delaying alignment with global frameworks.
CSDDD is narrowed to only the very largest firms, above 5,000 employees and €1.5 billion turnover, with no civil liability and no binding transition-plan obligations.
Climate-transition planning requirements are deleted, taking pressure off firms to publish credible climate pathways.
Supply-chain accountability is weakened, leaving most European SMEs outside any mandatory human-rights or environmental due-diligence duties.
This shift is being framed as simplification, although in practice it marks a step away from the EU’s previous leadership on transparency, comparability and sustainability governance.
Why It Still Matters
Even with weakened rules, sustainability expectations do not vanish. Investors, multinationals, public institutions and consumers continue to demand reliable data. Supply-chain pressures will tighten because large companies still have to protect themselves from reputational risk. The global direction of travel is still toward disclosure, due diligence and climate alignment.
This moment offers clarity, but only clarity about a smaller regulatory footprint. It does not remove the broader business risk.
Preparedness Now
A short guide to help SMEs and mid-sized organisations stay ahead despite reduced obligations.
1. Keep a basic ESG baseline
Even if you are out of scope, it is still useful to maintain a simple baseline covering:
annual emissions snapshot (Scope 1 & 2 at minimum)
basic waste and resource-use data
key human-rights and worker-safety controls
a short, public ESG statement updated yearly
The aim is not perfection. It is continuity.
2. Track what your buyers require
Large companies still face expectations, even under weaker rules. That means many will push their suppliers for:
basic sustainability disclosures
governance evidence
human-rights risk screening
proof of responsible sourcing
Being able to respond quickly protects your contract position.
3. Keep a simple risk map
Map three areas: environmental risks, social risks, and governance gaps. Keep it short. Update it once a year. This allows you to respond to new rules without starting from zero.
4. Maintain credibility with clients and funders
Banks, investors, and grant-giving institutions increasingly ask for sustainability evidence. A light ESG framework helps you stay eligible even if legal obligations move.
5. Use voluntary standards as low-cost insurance
Choose one voluntary anchor, such as:
GRI basic indicators
UN Global Compact principles
ISO 14001-style environmental controls
a small set of ESRS datapoints (even if not mandatory)
Voluntary alignment makes future compliance easier and protects your reputation.
6. Build a micro-transition plan
It does not need to follow the now-deleted EU rules. A short plan covering energy use, efficiency improvements and waste reduction protects you from cost shocks and shows clients you take climate risks seriously.
What SMEs Can Still Do Outside the Scope
Practical actions that still create value even without mandatory rules.
Keep your story clean
Even without CSRD or CSDDD obligations, poor sustainability performance carries reputational and commercial risk. A short, credible sustainability page on your website is still a competitive advantage.
Protect your supply-chain position
You can still proactively send buyers a one-page ESG overview. This reduces friction and improves trust during procurement.
Build trust in your workforce
Simple steps on health and safety, wellbeing, and fair hiring practices help retention and reduce turnover. These are practical, low-cost wins.
Use transparency as a differentiator
Many competitors will stop at the legal minimum. You can use simple transparency to stand out. A basic ESG summary, updated each year, signals reliability.
Prepare for the next cycle
EU rules may shift again after elections, judicial challenges, or market pressure. If you maintain a light ESG structure, you won’t face a scramble later.
169to1® ESG LAW & CIRCULARITY UPDATE 2025
13/11/2025
A concise guide to the latest EU sustainability developments
This update brings together the most important regulatory and framework changes affecting sustainability reporting, due diligence, circularity and business practice in 2025. It is designed to sit alongside the existing 169to1® ESG Law materials and gives organisations a clear understanding of what has changed, what remains stable and what they should prepare for next.
1. Corporate Sustainability Reporting Directive (CSRD): Current Status
The EU has announced a simplification package that will reshape how CSRD applies, particularly for smaller companies. The core structure of the directive remains in place, but several practical elements are being adjusted.
What has changed
Reporting thresholds are expected to rise, which means fewer small companies will fall directly within scope.
SMEs are not required to report immediately and may follow voluntary standards until at least 2028.
The European Commission is reducing and simplifying the number of mandatory disclosure points to make reporting more manageable.
The principles of double materiality, transparency and accountability remain unchanged.
What this means for organisations
Businesses should continue preparing for CSRD-aligned reporting, but they should check updated thresholds and timelines as Member States begin transposing the revised rules. Even when not in mandatory scope, many companies will still be required to align with CSRD standards through supply-chain expectations.
2. European Sustainability Reporting Standards (ESRS): Clarification
The ESRS now form the mandatory technical standards under CSRD. They define how companies assess impacts, risks and opportunities, how disclosures are structured and which data categories must be reported for governance, environmental and social performance.
Why this matters
CSRD is the law, but ESRS tell organisations what they must actually report. Any reference to CSRD should now be paired with clear acknowledgement of ESRS 1–12 to avoid misunderstanding and to maintain alignment with EU terminology.
3. Corporate Sustainability Due Diligence Directive (CSDDD)
CSDDD was formally adopted in 2024. Member States will incorporate it into national law between 2026 and 2028.
It establishes legal expectations for human rights and environmental due diligence across supply chains.
Impact on SMEs
Most SMEs will not be directly regulated under CSDDD, but they will be affected indirectly. Larger companies will extend due-diligence requirements down their supply chains, which will place expectations on smaller firms to demonstrate responsible sourcing, labour standards, and environmental safeguards.
4. EU Taxonomy: New Environmental Delegated Acts
The EU has expanded the Taxonomy with additional environmental criteria linked to circular economy, pollution prevention, biodiversity, and water management. These new criteria sit alongside the existing climate objectives and broaden the range of activities that can be classified as sustainable.
Practical relevance
The Taxonomy is increasingly used in sustainable finance, bank lending criteria and investment screening. Businesses should review whether the expanded technical screening rules now apply to their operations, particularly in manufacturing, infrastructure, waste, agriculture or resource-intensive sectors.
5. Global Circularity Protocol for Business (2025)
The World Business Council for Sustainable Development, working with the United Nations’ One Planet Network, has released a global circularity framework designed for businesses of all sizes.
It provides a consistent method to define, measure and report circular performance.
What the protocol enables
Identification of circularity hotspots in products and value chains.
Development of circular strategies, targets and KPIs.
Measurement of circularity using globally comparable indicators.
Clear communication of circular progress in line with international expectations.
Why it matters to your ESG materials
Although the protocol is voluntary, it aligns closely with ESRS E5 and emerging circular-economy indicators in the EU Taxonomy. It is expected to become a reference point for organisations wishing to show credible progress on resource efficiency, product lifecycle management and waste reduction.
6. What Organisations Should Do Next
To stay aligned with the evolving landscape, organisations should:
Review their current ESG reporting approach and check whether updates to CSRD thresholds or timelines affect their obligations.
Familiarise themselves with ESRS 1–12 to understand the level of data and disclosure expected.
Prepare for contractual due-diligence requirements from partners who fall within CSDDD scope.
Check whether their sector is included in the EU Taxonomy’s expanded environmental criteria.
Consider adopting the Global Circularity Protocol to strengthen circularity reporting and align with international benchmarks.
7. How This Update Fits Within the 169to1® System
This guide supports all users of the 169to1® ESG Law Cheat Sheets, Business Packs, NGO Packs and Compliance Appendix.
It ensures that every part of the ecosystem continues to reflect the latest developments in EU sustainability law and global circularity practice.
A fuller revision will be issued once the EU finalises the CSRD simplification package and Member States complete transposition. Until then, this update should be read as the current reference point for 2025.
169to1® ESG Update 2025: Student Edition
This guide explains the most important changes happening in sustainability and business rules in 2025. It is written so that young people can understand how companies are expected to act, report and take responsibility for people and the planet.
13/11/2025
1. What is CSRD and what is changing?
CSRD is a set of rules in the European Union that tells companies what they must report about the environment, social issues and how they run their business.
In 2025 the EU is making CSRD a bit simpler.
What is changing:
Smaller companies may not have to follow the rules straight away.
Some may not have to report at all until later.
The list of things companies must report will be shorter and easier to follow.
Companies still need to show how they affect people and the planet.
Why this matters:
It helps make sure businesses tell the truth about their impact and do not hide important information.
2. What are ESRS?
ESRS are the detailed instructions that explain how companies report under CSRD.
Think of CSRD as the rulebook, and ESRS as the step-by-step guide.
Why it matters:
ESRS tells companies what information they must collect, such as their carbon footprint, how they treat workers or how they use resources.
3. What is CSDDD?
CSDDD is a new EU law about responsible supply chains.
It supports human rights and environmental protection.
What companies must do:
Check their suppliers are not harming workers or the environment.
Fix problems when they find them.
Prove they acted responsibly.
Why this matters for young people:
It helps stop child labour, unsafe workplaces and environmental damage in countries where companies buy their products.
4. What is the EU Taxonomy?
The EU Taxonomy is a list of activities that are considered environmentally friendly.
In 2024 it was expanded to cover more areas like:
protecting nature and wildlife
reducing waste and pollution
using water responsibly
supporting the circular economy
Why it matters:
Banks and investors use the Taxonomy to decide which projects deserve green funding.
It helps money flow to cleaner and fairer industries.
5. What is the Global Circularity Protocol?
This is a new worldwide guide that helps companies measure how well they use resources.
It helps companies to:
see where they waste materials
design products that last longer
reuse or recycle more
set clear goals to reduce waste
compare their progress with other companies
Why it matters:
We cannot keep taking, using and throwing things away.
This protocol helps businesses move towards a circular economy where materials stay in use for much longer.
6. Why should companies care about all of this?
Because customers, workers, students and communities expect companies to act responsibly.
These rules and frameworks:
protect workers
reduce pollution
improve transparency
support fairer global supply chains
encourage better decisions about the environment
For young people, this means a healthier planet, safer workplaces, and more honest businesses in the future.
7. What you should take away from this
CSRD is being simplified but still important.
ESRS tells companies exactly what to report.
CSDDD makes supply chains safer and fairer.
EU Taxonomy guides green investment.
Global Circularity Protocol helps companies cut waste and reuse more.
These changes shape how companies behave today and how your future career might look tomorrow.