Money, Power, and the Future of Sustainability

Hello reader 👋

At the beginning of the year, we asked ourselves:

Will sustainability remain a compliance-driven function, or finally evolve into a true strategic driver of impact?

2025 gave us a very clear answer. Sustainability has no choice anymore. It either brings commercial value to the business, or it quietly slips into the unglorious “minimum requirements” bucket.

Read our annual update below on how the year unfolded, where sustainability stands today, and what to expect next.

HOW 2025 UNFOLDED

REGULATIONS were mainly rolled back in the West and tightened in the East. An excruciating Omnibus process in Europe, relentless CBAM progression, and tightening emissions oversight for heavy industry in China ahead of schedule.
→ See “Regulatory Volatility” below.

COP was underwhelming, to say the least, and yet again exposed the gap between global commitments and coordinated action, with metals, mining, and critical minerals at the centre of the transition discussion.
→ See “COP Without Momentum”.

MARKETS moved ahead regardless. Climate, supply chain, and transition risks were priced in, with or without regulatory clarity. Nature did not accept the arguments of “climate change being a hoax”: there wasn’t a month without a historic drought, heatwave, flooding, or hurricane.
→ See “Markets set the direction”

CORPORATES revised targets to link them more closely to risk, cost, and revenue. Initiatives that didn’t show value were cut.
→ See Disclosure and Due Diligence sections

All of this we predicted in our MATURITY CURVE, which you’ve seen already too many times (doesn’t make it less true): sustainability has passed its hype phase. Efficiency, business case, and AI-driven execution are now the priority.

→ If you want a deeper take on how teams and leaders are reacting, see our Sustainability Outlook 2025: AI, Money, and The End of Sustainability as We Knew It. Download the Sustainability Outlook 2025 here.

KEY DEVELOPMENTS THAT SHAPED 2025

Regulatory volatility

In 2025, sustainability regulation stopped feeling linear. Across regions, rules were delayed and sped up, softened and tightened, or left unresolved, creating an environment where planning became harder than compliance itself.

In Europe, the Omnibus process endlessly tried to reshape CSRD, CSDDD, and the Taxonomy without giving companies any form of stability. Germany suspended its national due diligence law (LkSG), battery due diligence requirements were pushed to 2027, and discussions around EUDR exemptions and the withdrawal of the Green Claims Directive left businesses without clarity and the ability to plan.

The US exited the Paris Agreement again, rolled back DEI requirements, eased anti-bribery enforcement, and withdrew climate risk principles for banks. At the global level, the IMO postponed its net-zero framework for shipping.

At the same time, in Asia, regulatory pressure continued to build. China expanded the scope of its national carbon market to cover additional heavy industries, increasing compliance and data requirements for sectors such as steel, cement, and aluminium. Singapore and Hong Kong moved ahead with mandatory climate disclosures aligned with ISSB standards, leaving the world with fragmented regulations and a changing vector for disclosures.

Diminishing return on disclosure

While regulation wavered, disclosure systems became more demanding.

CDP scores fell sharply in 2025 because methodology changes raised data requirements without transition periods. For many teams, effort stopped translating into outcomes. Manual reporting approaches struggled to keep up, and confidence in predictability weakened. Across our clients and the industry in general, we’ve heard more and more discussions about whether the costs of doing CDP justify the outcome; very much aligned with the overall sustainability business reorientation.

There were many early CSRD-aligned reports this year. They demonstrated that any hope for “comparability” was far-fetched, with regulations being too vague and lacking industry standards to provide any analysis-level standardisation. The reports also widely acknowledged climate risks, but rarely quantified them in financial terms. With CSRD being significantly weakened, a question every team should ask itself is what reporting is necessary, what value it creates, and how to optimise this process around a limited target number of reports.

My big prediction for 2026 is a radical reduction in the number of disclosures in favour of a few high-value ones, including the merging of reports and frameworks (such as the upcoming Consolidated Mining Standard). It is also clear, however unpleasant, that oversized reporting teams will be significantly reduced. As C-level leaders focus on costs this year, sustainability executives who are not optimising their processes with AI and not making their teams proficient in AI will very soon feel the consequences of inaction.

COP without momentum

COP30 in Brazil was, let’s say, anticlimactic. Political momentum was muted, participation by global leaders was limited, and progress on climate finance and updated national targets remained slow. No agreement was reached on the transition plan, and nothing serious came out of it.

Yet, mining and critical minerals moved closer to the centre of climate discussions. The transition increasingly depends on long and complex value chains, where climate goals intersect with supply security, environmental impact, and social risk. While this connection was acknowledged more clearly, it did little to reduce uncertainty for businesses operating across fragmented policies and markets.

Many would say that the summit reinforced the gap between global ambition and coordinated delivery. I’d say that the ambition itself is being put to the test, and a commercial one this time: who benefits from the transition and who pays for it? And mind it, saying “the world” and “future generations” won’t cut it, because they can’t pay. You might call me cynical, but that’s another result of 2025: we all realised that being cynical and pragmatic is the only way to get to sustainability goals, beyond big announcements and unsubstantiated promises.

If COP is to survive as an institution, in 2026, it needs to form a business-case angle on a global scale, with practical value mechanics. And it might be, without exaggeration, one of the most difficult tasks of our generation: the risks are unevenly distributed and probability-driven, while benefits are felt only in the long (very, very long) term. However difficult, I’d say we have to take our chances with it, and being pragmatic and commercially driven as sustainability teams is only going to help us get there.

Markets set the direction

Commercial climate mechanisms continued to advance, confirming the increasingly commercial lens sustainability is taking on. 

CBAM moved steadily toward its cost phase, even as exemptions expanded to remove most importers from scope. The focus narrowed to major emitters, reinforcing that carbon exposure will increasingly influence trade and procurement decisions. Starting this January, we see that CBAM is in full force and is creating significant tension for unprepared players.

Market infrastructure also followed. The London Metal Exchange introduced emissions reporting requirements aligned with CBAM, and discussions around green premiums became more pragmatic. The focus shifted to where verified sustainability performance could translate into commercial outcomes. It also extended beyond carbon to factor in responsible sourcing and supply chain practices.

In 2026, these mechanisms are likely to appear in more industries, and I expect more attempts to go beyond carbon, similar to what we are starting to see in the LME approach.

Due diligence in focus

Tightening budgets, regulatory uncertainty, critical supply risks, and the accumulated craziness of 2025 affected how companies managed their value chains. 

As companies rethought them in light of tariffs and CBAM, we saw an uptake in voluntary and bespoke risk frameworks, as new suppliers in new locations brought new compliance challenges. There was increased pressure from forced labour regulations in the EU and the US (Uyghur Forced Labor Prevention Act), alongside multiple bills advancing in South Korea, Indonesia, and Thailand. This regulatory instability forced companies to allocate more resources to building bespoke frameworks to assess suppliers and go several tiers upstream.

For many years, this meant spending increasing resources on due diligence: moving toward exhaustive due diligence on the graph below, which entails extraordinary costs and effort. A purely strategic approach without broad analysis was unfeasible and risked too many blind spots.

In 2026, most teams will not receive the budgets required and simply cannot afford an exhaustive approach, going deeper and wider at the same time. Strategic due diligence will likely become the only viable option for large players, supported by AI to cover blind spots and reduce the risk of missing issues

We cover this shift in our upcoming report, Due Diligence in 2026. The report examines how companies are adjusting the scope and depth of due diligence, how they focus on key risks, and how AI is used to prioritize attention and improve reuse of supplier data, with implications for traceability and supply chain management.

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LOOKING AHEAD: SUSTAINABILITY IN 2026

What we’ll see more of:

• AI
• Water
• Nuclear
• Due diligence
• Smaller teams

What we’ll see less of (or none at all):

• Regulatory certainty
• Big budgets
• Consulting
• Vague, colorful reports without metrics
• “Sustainability is in our DNA” (though it might be my wishful thinking)

BESIRIUS UPDATES

We became beSirius - rebranded and introduced our little sarcastic (s)tone 🗿

‍We published:

• Sustainability Outlook 2025
• Practical roadmap for sustainability leaders in 2025
• RMI Templates Guide
• UN Global Compact Handbook
• S&P Corporate Sustainability Assessment Success Guide

We launched the Executive Sustainability Dialogues Webinar Series:

• AI, money and the end of sustainability as we knew it (featuring Amanda Gardinier, Executive Director at UN Global Compact and ex-Head of ESG at Meta, and Luca Marioni, Sustainable Business Developer at ArcelorMittal)
• Making sustainability commercial: the metals industry perspective (featuring Hugo Brodie, Head of Sustainability and Physical Market Development at the London Metal Exchange (LME), and Felix Schmitz, CEO at Kloeckner Metals Germany)

Where to meet us next:

🇸🇦 Future Minerals Forum (January 13-15)

🇿🇦 Mining Indaba (February 9-12)

🇨🇦 PDAC (March 1-4)

🇩🇪 Wire & Tube (April 13-17)

🇪🇸 Cobalt Congress 2026 (May 12-13)

🇧🇪 EIT Raw Materials ( May 19-22)