The pace of change with regard to attitudes, laws and
regulations on climate change matters in the ten years since the
adoption of the Paris Agreement in 2015 has been head spinning. In
the early years of the past decade, there appeared to be a growing
international consensus on the need to finance the transition to
net zero. In its ambitious Sustainable Finance Action Plan,
published in 2018, the European Union
(“EU”) sought to position itself as a
global leader in the area of sustainable finance, introducing a
complex framework of new disclosure rules intended to provide
investors with the information they needed to make investments
aligned with their sustainability goals. In the US, at a federal
level, the SEC proposed rules aiming to standardise how companies
report their climate-related risks and impacts, while a large
number of states introduced sustainability reporting regulations.
The Inflation Reduction Act (“IRA”)
introduced significant tax incentives to