Issue link: https://iconnect007.uberflip.com/i/1543584
50 SMT007 MAGAZINE I MARCH 2026 maximum of 3% of net worldwide turnover, and civil liability is narrowed by deferring to national law. • Maximum harmonization: Full harmonization is extended to additional provisions govern- ing the core elements of the corporate due diligence process, i.e., Member States can no longer introduce national rules diverging from the Directive in these areas. • Other key changes: The obligation to adopt climate transition plans is removed, the def- inition of "stakeholders" is narrowed, the stakeholder consultation obligation is tight- ened, termination of a business relation- ship is no longer required, suspension is the only last-resort measure, and monitoring fre- quency is reduced to once every five years. What It Means for the EUT The current agreement eliminates the EC's pro- posed provisions on optional taxonomy reporting. It thus remains mandatory for all EU and non-EU entities listed on an EU-regulated market that have a net turnover exceeding €450 million and 1,000 employees on average during a financial year. On July 4, 2025, the EC adopted an EUT Delegated Act to finalize proposals to simplify the EUT. On Dec. 17, 2025, the EC published a draft Commission Notice to provide interpretation and implementation guid- ance on the amendments to the EUT Delegated Act in the form of frequently asked questions (FAQs). The EUT Delegated Act had an effective date of Jan. 1, 2026, and covers reporting for the 2025 financial year. However, entities may apply the measures starting with the 2026 financial year. In addition, on Nov. 7, 2025, the EC published two calls for evidence on proposals to simplify the technical screening criteria of the EUT Climate and Environmental Delegated Acts. The deadline to provide comments was Dec. 5, 2025. In response to the calls for evidence, two delegated acts will be drafted, each with a four-week public consultation period. The final delegated acts should be adopted by the EC in Q2 2026. CBAM CBAM is an EU regulation designed to prevent carbon leakage by placing a carbon price on cer- tain imported goods. It aligns the carbon cost of imports with the EU Emissions Trading System (EU ETS), ensuring equal treatment between EU and non-EU producers. CBAM currently applies to high-emission goods, including cement, iron and steel, aluminum, fertilizers, electricity, and hydro- gen. Importers must report the embedded green- house gas (GHG) emissions of these products and, for imports made from 2026 onwards, pur- chase CBAM certificates to cover those emissions. The CBAM Omnibus Regulation, adopted in 2025 and now in force, together with the implementing acts published on Dec. 17, 2025, introduces bind- ing simplifications and operational clarity ahead of the definitive phase. Key CBAM regulation updates include a binding, de minims exemption (50 tons/ year), an updated timeline, and clarified emission data and verification rules.