Sustainability/ESG

As ESG continues to rise on the corporate agenda, many organisations find the “S” in ESG the hardest to define and operationalise. While environmental impact and governance frameworks often have clear pathways, social impact can feel far more elusive. In this article in our illuminate publication, ESG consultant and former GC Steven Webb shares his insights on how companies can bring clarity to the “S” and why volunteering can deliver meaningful social value while strengthening organisational performance.

On 18 March 2026 the Omnibus I Directive, which simplifies the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD) came into force. Key changes include raising the reporting threshold to over 1,000 employees and €450 million turnover, and limiting due diligence to firms with over 5,000 employees/€1.5 billion turnover. Member States must transpose the CSRD provisions into national law by 19 March 2027 and the CSDDD changes by 26 July 2028. Compliance is required by 2029.

We’ve reported periodically on the progress of the alleged forced labour litigation against Dyson in respect of its Malaysian supply chain. Following the High Court’s ruling, earlier this year, that the claim would proceed to trial, Dyson has now reached an out-of-court settlement. Dyson’s settlement doesn’t determine liability, but it, and the publicity the claim received, underscores the need for businesses to address ESG issues not only in-house, but also throughout their supply chain. See here for further knowhow support on the subject.

The Competition and Markets Authority (CMA) has published guidance on best practice when making green claims across the supply chain. In related news, EU member states are starting to implement new green claims rules under the Empowering Consumers for the Green Transition Directive, which must come into force by 27 September 2026. In the UK, the FCA has published examples of good and poor practice for using sustainability labels under the UK Sustainability Disclosure Requirements regime.

Corporate/corporate reporting

The International Sustainability Standards Board is consulting, until 24 July 2026, on proposed amendments to the Sustainability Accounting Standards Board (SASB) Standards and to the Industry-based Guidance on Implementing IFRS S2 for three priority industries: agricultural products; meat, poultry and dairy; and electric utilities and power generators.

At the end of February 2026, the government endorsed the UK Sustainability Reporting Standards (UK SRS) for voluntary use. As yet, however, the government hasn’t mandated how the UK SRS will be applied to UK corporates in practice. In related news, the FCA has released Consultation Paper 26/5 , setting out proposals for UK SRS-aligned reporting requirements to be applied to companies with shares listed in the UK from January 2027. The consultation closes on 20 March 2026. We’ll continue to monitor and report on developments.

The Financial Reporting Council has published updated guidance to assist investors, proxy advisors and other users of corporate reports to understand ‘comply or explain’ reporting used by companies departing from provisions under the UK Corporate Governance Code.

The Office of Financial Sanctions Implementation published a call for evidence to seek views on how UK financial sanctions regulations on ownership and control are applied in practice, including how firms implement the regulations and where they face challenges. The call closes on 13 April 2026.

The government has published updated statutory guidance on the meaning of ‘significant influence or control’ over companies in the context of the regime for people with significant control (PSCs).

On 3 March 2026, the FCA announced it will bring forward a review of certain aspects of the UK Listing Rules as they apply to investment entities.

The Insolvency Service has published a consultation  on proposed reforms to the corporate civil enforcement regime, including in relation to director disqualification. It forms part of the Insolvency Service’s strategy to tackle corporate abuse. The consultation closes on 17 June 2026.

Data protection/cyber security/tech and digital

The government has published a Smart Data Strategy. It sets out a long‑term vision for smart data in the UK, and actions government will take to unlock growth, competition and innovation through secure data sharing across the economy.

The Court of Appeal has, in DSG Retail Ltd v Information Commissioner, allowed the ICO’s appeal and confirmed data controllers must safeguard personal data against unauthorised processing based on whether they can identify individuals, not whether third parties can. The decision clarifies that the security duty under the DPA 1998/UK GDPR is assessed from the data controller’s perspective. Controllers must implement appropriate security measures to protect all personal data they hold, even against threats where attackers cannot identify data subjects, providing greater protection against cyber-attacks, ransomware and data theft. Data controllers can’t avoid security obligations by arguing stolen data would be non-personal in attackers’ hands.

The ICO has published guidance the ‘recognised legitimate interest’ lawful basis introduced by the Data (Use and Access) Act 2025.

The ICO has published a joint statement on the approach of it and other global data authorities to AI systems that generate images/videos without an individual’s knowledge or consent. It expects organisations to: consider data protection laws when developing/using gen-AI; implement robust safeguards; be transparent about the AI system’s capabilities; have processes in place for individuals to object to harmful content; and address specific risks to children.

Ofcom and the ICO have written to major tech platforms to ask them to enforce their minimum age rules with highly effective age checks. An updated joint statement is due to be published in March 2026, outlining areas of interaction between online safety and data protection relating to age assurance.

The ICO is consulting until 29 May 2026 on draft guidance about automated decision-making.

The draft guidance is intended to help organisations understand and meet their obligations when carrying out automated decision-making.

Agentic AI goes beyond generative AI – beyond merely responding to queries. It senses its environment, makes decisions, and acts. It can autonomously plan and take actions across multiple services – assessing goals, breaking them into subtasks, planning workflows, retrieving data, executing actions, and memorising to improve over time. The CMA has published guidance and research about how businesses can use agentic AI whilst complying with consumer protection law.

The House of Commons Business and Trade Committee has launched an inquiry into AI, open until 3 April 2026. The aim is to understand the opportunities and costs for businesses and the workforce, and to make recommendations on government priorities.

The House of Lords Digital and Communications Committee (the Committee) has published a report on AI, copyright and the creative industries.

In related news, the government has published its report on copyright and AI, rowing back from its previously-preferred position of allowing tech companies to use copyrighted material to train their AI platforms.

For more on tech developments, see the latest edition of our Tech & Digital roundup.

Commercial/general

The UK Government has published its response to the consultation on proposed changes to the National Security and Investment Act 2021 (Notifiable Acquisition) (Specification of Qualifying Entities) Regulations 2021, which define the sectors subject to mandatory notification under the National Security and Investment Act 2021 (NSIA). The NSIA gives the Government powers to scrutinise and intervene in acquisitions that may pose a risk to national security in the UK. See our article for more information.

The government published its fraud strategy for 2026 – 2029, which aims to reduce crime, restore confidence, and improve economic resilience.

The CMA is consulting on revised Unfair Contract Terms guidance under the Consumer Rights Act 2015. Proposals include a refreshed approach to assessing fairness in digital consumer contracts. The consultation closes on 19 March 2026 and, once finalised, the new guidance will replace CMA37.

Also in CMA news, the regulatory has published its 2026-27 Annual Plan. It prioritises, in markets work: remedies in the veterinary services market, completion of the civil engineering market study, and conduct work on the private dentistry market; enforcement in relation to practices that prevent innovative firms entering and scaling markets, public procurement, and algorithmic price collusion; and, in relation to digital markets, design and implementation of interventions following its initial Strategic Market Status designations.

The Provision of Services Regulations 2009 regulate services in the UK – in particular authorisation schemes that control licensing of service providers by local authorities and regulators. They also impose information provision and complaint handling obligations on businesses, and apply to services provided for remuneration (other than those specifically excluded). From 1 October 2026, the Regulations will be expanded in scope, clarified and updated. Draft amending regulations were published on 6 March 2026: The Provision of Services (Amendment and Transitional Provisions) Regulations 2026. Guidance is expected before the changes come into effect.

We’ve reported previously that the EU Green Claims Directive is on hold. However the Empowering Consumers for the Green Transition Directive, which Member States must transpose by 27 March 2026 (with rules applying from 27 September 2026), will significantly reinforce the EU consumer‑protection framework in relation to environmental marketing in any event. From 27 September 2026, every EU point‑of‑sale journey must prominently display the new legal‑guarantee notice exactly as prescribed. Wider greenwashing prohibitions apply from the same date. Click here for further information and guidance.  

The Welsh draft Digital Waste Tracking Regulations have been laid before the Senedd. The draft Regulations are expected to come into force on 1 October 2026. They’ll introduce the first phase of a digital system to record the movement of controlled waste in Wales.

The Department for Transport has announced a grant towards the cost of installing EV chargers for households and businesses. Key points include: renters, landlords and businesses will be able to claim up to half the cost of installing an electric charger – saving them up to £500 as grants extended for a further final year; and simplifying updates to the grant offering system, making it easier for people and businesses to access.

The government has published its ‘Time to pay up’ response to its consultation on late payments. The government will legislate, as soon as parliamentary time allows, to introduce a 60-day payment cap and transparency measures, as well as a ban on the deduction/withholding of retention payments in the construction sector. For more information, see our recent article.

The Provision of Information (Contractual Control) (Registered Land) Regulations 2026 have been published. They introduce a new transparency/disclosure regime for contractual control agreements over land in England and Wales. They require disclosure of certain information about contractual control rights to HM Land Registry and publicly via a new database. The Regulations will come into force on 6 April 2027, but disclosure obligations will also apply to relevant agreements entered into between the date the Regulations are made (expected in the first half of 2026) and commencement. See our article for more information.

We’ve reported previously on the Construction Products Reform Green Paper on wide-ranging plans for future regulation of construction products. Proposals include bringing all construction products within the general product safety regime; enhanced regulatory, surveillance and enforcement powers; development of a new single Construction Products Regulator; and civil and criminal penalties for manufacturers that engage in misleading practices or neglect their responsibilities regarding product safety. The government is consulting, until 20 May 2026, on its proposals.

The Department for Environment, Food & Rural Affairs has published a new Waste Crime Action Plan, which signals a significantly enhanced, and resourced, waste crime surveillance and enforcement regime. The government has already announced mandatory waste tracking from October 2026, but other measures set out in the plan, such as strengthened rules for waste carriers, brokers and dealers, funding increases and new police-style powers, don’t yet have confirmed start dates.

The government is consulting on introducing a digital identity  system to enable easier, secure and trusted access to a wide range of public services, while also making right to work checks digital. The consultation runs to 5 May 2026.

People

The Employment Rights Act 2025 (ERA) is making sweeping changes to UK employment law. To help you navigate the changes, we’ve created a tracker to keep you updated on the proposals, what they mean for employers and how you can prepare, organised by topic and timeline. Access our tracker here.

A raft of employment law changes will come into force in April 2026. In this article, we summarise the key developments and outline what you should be doing now to make sure your organisation is prepared.

The government is consulting, until 21 May 2026, on how the new organisation-wide threshold for triggering collective redundancy obligations under the ERA might be set.

The government has published guidance for large employers on gender equality action plans which will be introduced, under the ERA, on a voluntary basis from April 2026, and which will become mandatory from 2027.

The Bereaved Partner’s Paternity Leave Regulations 2026 come into force on 6 April 2026. They provide a right to up to 52 weeks’ bereaved partner’s paternity leave where the child’s primary carer has died within 52 weeks of the birth or adoption placement.

The FTSE Women Leaders Review has published a report on gender balance on boards and in leadership teams of the FTSE 350 and 50 of the UK’s largest private companies.

The government has published its response to its consultation on mandatory ethnicity and disability pay gap reporting. It intends to go ahead with introducing mandatory ethnicity and disability pay gap reporting for employers with 250 or more employees, but no timeline has yet been given.

The government has published its response to the House of Lords Committee on Home-based Working, reiterating its commitment to the promotion of flexible working practices, including remote and hybrid working. This aligns with ERA 2025 provisions, expected to come into force in 2027, introducing a reasonableness requirement for employers rejecting statutory flexible working requests.

The Parker Review Committee has published its 2026 annual report on improving the ethnic diversity of UK business. It reports progress across the FTSE 350 of ethnic minority representation at board level, but a notable variation between different ethnic groups.

The High Court has rejected an application for judicial review of the interim advice published by the EHRC following the judgment in For Women Scotland Ltd v Scottish Ministers. The EHRC published its interim update on the practical consequences of the Supreme Court’s decision (Interim Update) on 25 April 2025. This was amended on 24 June 2025 and withdrawn on 15 October 2025. Before withdrawing the Interim Update, the EHRC provided a revised Code of Practice on services, public functions and associations to the government. This awaits approval.

The Good Law Project Ltd and three individual claimants challenged the Interim Update on the basis that it was wrong in law, its publication breached the EHRC’s obligations under the Equality Act 2006, and/or was incompatible with Article 8 of the European Convention on Human Rights (ECHR). Further clarification on the obligations of employers and service providers in relation to these issues is needed. In the meantime, this decision confirms that the law as stated by the EHRC in the Interim Update was, and remains, correct, even though the Interim Update has been withdrawn. Developments in this area should be closely monitored.