The United Kingdom of Great Britain and Northern Ireland (the “UK”) is a party to the UN Framework Convention on Climate Change (UNFCCC) (signed 12 June 1992; ratified 8 December 1993) and the key agreements under the UNFCCC, including the Paris Agreement (26 April 2016; ratified 18 November 2016).

The UK has played a significant role in the UNFCCC negotiations over the years, primarily as part of the EU bloc. The UK was also one of the first nations to commit to reducing national climate change-inducing greenhouse gas emissions (GHGs) under law, through the Climate Change Act 2008 (see 1.2 Regional Climate Change Legal Regimes) and it was the first G20 nation to halve emissions in 2023 compared to 1990 levels. At COP30, it pushed for several mitigation and adaptation measures. 

Mitigation

At COP 30, the UK championed to work with others on the following initiatives.

• Tripling renewables and doubling energy efficiency globally by 2030, including through the Global Clean Power Alliance.
• In providing an updated ambitious Nationally Determined Contribution (NDC) for 2035 to reduce GHG emissions by at least 81% compared to 1990 levels for the UK, to assess the 2035 NDCs submitted by countries and determine how to close the gap.
• Halting and reversing forest loss by 2030 including through its role as co-chair of the Forest and Climate Leaders’ Partnership.
• Scaling up finance to fulfil the COP29 call for USD1.3 trillion for developing nations climate action by 2035 (see Climate finance below).

Adaptation

At COP 30, the UK also championed to work with others on finalising global indicators to measure adaptation through the Global Goal on Adaptation and to accelerate the development and implementation of National Adaptation Plans.

Climate finance

The UK seeks to deliver on its commitments under the Paris Agreement to help developing nations through the UK International Climate Finance (UK ICF). In the UK’s Biennial Finance Communication to the UNFCCC submitted in December 2024, the UK pledged to increase its UK ICF contribution from GBP5.8 billion over the 2015 to 2021 period to GBP11.6 billion over the 2021 to 2026 period. In March 2026, the UK government announced that by 2027 it would reduce spending on development assistance in favour of increasing spending on defence in the face of growing global security threats.

The UK also co-chairs the Taskforce on Access to Climate Finance which has published a set of Principles and Recommendations to underpin how climate finance providers and recipients might access and use climate finance more effectively.

The UK did not commit funds to the Tropical Forests Forever Initiative led by Brazil to financially incentivise forest rich countries to continue to preserve their forests.

Capacity-building

The Glasgow Climate Pact (established during COP26) included a call for increased grant-based climate finance. Funded by the UK ICF, the UK’s Partnering for Accelerated Climate Transitions (UK PACT) aims to improve the capacity of key public, private and civil society institutions to reduce emissions. It operates in countries with high emissions and the potential for high emissions reductions. As at March 2026, the programme had spent ~GBP51m from a budget of GBP150m and is due to end in April 2027.

The UK has also signed and ratified the following climate-related conventions.

• Convention on Biodiversity (signed 12 June 1996; ratified 3 June 1996), under which the strategic action plan, the Kunming-Montreal Global Biodiversity Framework (GBF), was adopted in 2022. This framework sets non-binding objectives to halt biodiversity loss by 2030, to increase natural ecosystems by 2050, to stop human-induced extinction risk and, by 2050 to reduce extinction risk tenfold.
• Vienna Convention for the Protection of the Ozone Layer (signed 20 May 1985; ratified 15 May 1987) and the Montreal Protocol on Substances that Deplete the Ozone Layer (16 September 1987; ratified 16 December 1988).
• Ramsar Convention on Wetlands of International Importance (signed 6 September 1973; ratified 1976), the only international convention dedicated to a specific ecosystem.
• Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters, also known as the Aarhus Convention (signed 25 June 1998, ratified 23 February 2005) providing for public involvement in environmental issues including access to information and access to justice.

UK–EU Relationship

Prior to Brexit in 2020, the UK was involved in EU climate change initiatives as a full member of the EU, whereas now it co-operates with the EU as a third country. This relationship is governed by the Trade and Cooperation Agreement where the UK and EU agree to respect the Paris Agreement and UNFCCC process, promote the mutual supportiveness of trade and climate policies, and to fight against climate change in international fora.

The UK has developed a Carbon Border Adjustment Mechanism (CBAM) (see 2.3 National Land Regime) that is substantively equivalent to the EU’s CBAM, and it has agreed to link its Emissions Trading System with the EU’s Emission Trading System to allow carbon prices paid in each jurisdiction to be recognised in the other for the purpose of CBAM. The UK has also entered a North Seas Energy Cooperation Memorandum of Understanding with the EU to advance offshore renewable energy development in the North Seas.

UK Constituency

The UK’s NDC commitment under the Paris Agreement is an economy-wide emissions reduction target for England, Scotland, Wales, Northern Ireland and for those Crown Dependencies and Overseas Territories included within the UK’s ratification of the Paris Agreement. The Department for Energy Security and Net Zero (DESNZ) has oversight of the UK’s international and domestic energy and climate policy. Energy is a reserved matter while certain environmental aspects, including climate policy, are devolved to Scotland, Wales and Northern Ireland and to the Crown Dependencies and Overseas Territories. The Climate Change Committee (CCC) is an independent body established under the Climate Change Act 2008 advising the UK government and the devolved administrations on emissions targets. The approaches taken differ across these regions.

Northern Ireland’s Climate Change Act includes a net zero GHG emission reduction target by 2050 and a 48% reduction target by 2030. The NI Assembly approved a 77% GHG emission reduction target by 2040 against 1990 levels in December 2024. The Department for Agriculture, Environment and Rural Affairs will publish five-yearly Climate Action Plans which will set out how each carbon budget period will be achieved.

Amendments made to Scotland’s Climate Change (Scotland) Act 2009 by the Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 established a net zero GHG emission reduction target by 2045. The amendments also introduced a carbon budget based framework for setting targets. Carbon budgets cover a five-year period and are based on advice received from the CCC.

Wales’s emissions reduction targets are set through the Environment (Wales) Act (2016). In March 2021, the Welsh Assembly committed Wales to achieving net zero emissions in 2050. Carbon Budget 2 (2021–25) is subject to a 37% average reduction, with no international offsets, Carbon Budget 3 (2026–30) is subject to a 58% average reduction and 2030 is subject to a 63% reduction.

The English Devolution and Community Empowerment Act 2026 devolves further powers to a Strategic Authority in every part of England and the legislation was subject to criticism that it should have included duties to contribute to national and international climate targets.

Influence of Science and the IPCC

UK climate policy is informed by science and guided by advice from the CCC on emission reduction targets and on progress in meeting those targets. The UK government receives advice from the CCC in respect of the NDCs, including the recently updated NDC. While the CCC is an independent body, it is heavily influenced by the IPCC which makes its assessments on Paris Agreement-consistent metrics, goals and scenarios based on science. The IPCC’s 2018 Special Report on warming of 1.5 degrees Celsius, published in 2018, was a key piece of evidence underpinning the CCC’s recommendation to the UK government to adopt a 2050 Net Zero GHG emission reduction target, which is a cornerstone of the Paris Agreement.

The UK’s GHG Inventory is the basis on which the UK reports nationally and internationally on GHGs. It is compiled on behalf of the DESNZ according to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, as supplemented by the 2013 IPCC Kyoto Protocol Supplement and the 2013 IPCC Wetlands Supplement. The UK accounts for emissions and removals in accordance with the methodologies and common metrics assessed by the IPCC. 

The UK’s NDCs

The UK’s initial NDC which was submitted to the UNFCCC in December 2020 commits the UK to reducing GHGs by at least 68% by 2030, compared to 1990 levels. The UK’s 2035 NDC announced at COP29 and formally submitted to the UNFCCC in January 2025, seeks to cut emissions by at least 81% below 1990 levels by 2035. The UK’s 2030 and 2035 NDC targets are unconditional and not contingent on actions by any other state.

The focus of the UK’s NDC is on climate change mitigation. The UK sets five-year caps on emissions through carbon budgets prepared pursuant to targets set under the Climate Change Act, which targets are designed to deliver on the UK’s Paris Agreement commitments. The budgets are set 12 years in advance. In October 2025, the UK government released the Sixth Carbon Budget outlining the policies needed to achieve targets for the period 2033–2037. Key focus areas in the Sixth Carbon Budget are to support investment in renewable and nuclear power, increase employment in clean energy by 430,000 employees and to support investment in hydrogen and Carbon Capture Usage and Storage.

The UK is legally required under the Climate Change Act to adapt and strengthen resilience to climate change, produce a climate change risk assessment and five-yearly national adaptation programmes setting out how it will address climate change risks. The third National Adaptation Programme (NAP3) was published in July 2023 and covers the period 2023 to 2028. NAP3 sets out extensive plans to protect, restore and create coastal and marine habitats and manage the risks and opportunities arising in connection with marine species, habitats and fisheries. NAP4 is expected to be published in 2028. The CCC issued a progress report to Parliament in October 2025 stating that UK adaptation implementation is inadequate and the government must act without delay to improve objectives and targets, improve co-ordination, integrate adaptation into all relevant policies and implement monitoring, evaluation and learning across sectors. Two weeks later, the government issued detailed responses to the CCC’s recommendations including a commitment to explore stronger objectives to improve preparedness for the impacts of climate change.

The UK last submitted an Adaptation Communication to the UNFCC in 2020. This voluntary report contains the UK’s plans for climate change adaptation and for supporting climate change adaptation overseas. An update was published in 2021 and the UK will submit a further update in due course and, indeed, the CCC has recommended that the communication be updated, also as an opportunity to demonstrate international leadership. 

The UK published its first Biennial Transparency Report (BTR) in 2024. The purpose of these reports, which are mandatory under the Paris Agreement is to articulate to the UNFCCC and to the public, progress in reducing GHGs, approach to adaptation and support for developing countries in tackling climate change. The UK’s BTR includes progress tracking on meeting its 2030 target, National Inventory Data on emissions and trends, details of NAP3 and support for developing countries. The next report is due to be submitted this year.

The UK made commitments under the Paris Agreement to cut methane emissions by 2030 by joining the Global Methane Pledge (GMP) which was launched at COP26. The UK is a GMP Champion, designating high level officials to advance the GMP’s work. The UK released a Methane Action Plan in October 2025, which alongside the Carbon Budget and Growth Delivery plan (CBGDP), outlines the policies and proposals needed to reduce emissions, including those of methane, to deliver Carbon Budgets 4-6 and our Nationally Determined Contributions (NDC) on a pathway to net zero.

Climate Change Act 2008

The UK was one of the first nations to commit to reducing national climate change-inducing GHGs under law, through the Climate Change Act 2008, which is underpinned by a carbon budget-setting process that sets a legally binding, five-year cap on the quantity of GHGs which can be produced from UK-based assets.

Role of Climate Change in the UK Constitution

While the UK does not have a written constitution, it comprises written and unwritten conventions, treaties, statutes and common law. Certain commentators consider protection against the harm created by climate change to be a human right, and this argument has been led in a number of cases before the English courts. Namely, in R (Plan B Earth and others) v The Prime Minister and others [2021] EWHC 3469 (Admin), the High Court of England and Wales refused an application for judicial review by climate litigation charity, Plan B, in respect of the UK government’s investment decisions concerning roads, condition-free loans for fossil fuel based companies and a natural gas project in Mozambique. The claim was based on the grounds that the government’s financing of the climate crisis was a violation of their human rights (under the Human Rights Act 1998) and of UK law (Climate Change Act 2008) and international law (Paris Agreement). The court held all four grounds of the claim should be refused owing to procedural defects.

Other Legislative and Regulatory Tools to Frame the National Response to Climate Change

The UK also frames its national response to climate change through a number of other legislative instruments.

• Disclosures required by UK companies through climate-related financial disclosures (see 4.1 Climate Financial Reporting (Longstanding disclosure regimes));
• The regulation of the carbon footprint of heavy industry through the UK Emissions Trading Scheme (see 2.3 National Legal Regime (UK ETS));
• The incentivisation of low carbon energy generation through financial instruments (see 2.3 National Legal Regime (Incentive schemes)).

Mitigation

The UK was the first nation to commit to reduce national climate change-inducing GHGs, through the Climate Change Act 2008, which initially set a target to reduce GHGs by 80% by 2050. In 2019, this was amended so that the total amount of GHGs shall be net zero by 2050. This is underpinned by a carbon budget-setting process that sets a legally binding, five-year cap on the quantity of GHGs which can be produced from UK-based assets. Despite that much of climate change is a devolved matter, emissions are reported on a whole of UK basis.

Command and Control Measures

UK ETS

The UK established the UK Emissions Trading Scheme (UK ETS) in January 2021, which establishes caps on GHG emissions from regulated sectors including manufacturing facilities, power stations and aviation. Regulated businesses are required to (i) hold a GHG emissions permit, (ii) surrender an equal number of emissions allowances to the total volume of emissions generated from their in-scope installations in any given year and (iii) monitor, report on and verify the GHG emissions from regulated installations. Allowances can be purchased at auction and some are allocated for free by the EA. It is overseen by the UK ETS Authority, which publishes the carbon price every year. The EA and FCA are the regulators for the UK ETS.

The UK ETS also applies to GHG emissions from UK domestic flights, flights between the UK and Gibraltar and flights from the UK to the EEA.

Since 1 July 2026, the UK ETS covers domestic maritime transport on ships of 5,000 GT and above operating on domestic UK routes and in UK ports.

Other command and control measures applied to GHG emissions

Sector and non-sector specific regulatory regimes specify command and control measures in respect of GHG emissions from certain businesses – eg, the automotive sector is regulated by the Vehicle Emissions Trading Scheme Order 2023, which implements the UK’s net zero strategy through requiring a certain percentage of manufacturers’ new car and van sales to be zero emission from 2024. The Environmental Permitting Regulations 2016 also specify limits for emissions of certain GHGs by certain permitted installations – eg, nitrogen dioxide emission limits for certain combustion plants.   

Carbon tax/levies

The Climate Change Levy (CCL) is an environmental tax charged on the energy (electricity, natural gas, liquid petroleum, liquid hydrocarbon gas, solid fuels) that businesses use. The main rates of the CCL for gas, electricity and solid fuels were recently increased in line with the Retail Price Index however the rate for liquefied petroleum gas remains frozen. A Carbon Price Support (CPS) rate is applied to supply of fossil fuels for use in electricity generation in order to encourage the generation of low carbon electricity by increasing the price paid for emitting carbon dioxide.

Climate Change Agreements (CCA) are voluntary agreements between sector associations and the EA and embed targets for energy-intensive installations to improve energy efficiency or reduce their carbon footprint, in return for which they benefit from reduced CCL rates. The CCA scheme was expanded in April 2026 to capture production of automotive grade battery cells, packaging of spirits, and mechanical recycling of plastics.

UK Carbon Border Adjustment Mechanism

UK Government issued a consultation in March 2024 on the creation of a UK carbon border adjustment mechanism (UK CBAM), which would apply a levy on the GHG emissions embedded in certain carbon-intensive imported products from 1 January 2027. The levy seeks to create a situation where the price paid for the goods is comparable to what they would have cost had they been produced in the UK.

Associated changes to the UK ETS (eg, reduced free allocations of UK allowances), coupled with UK CBAM, seek to move the UK towards decarbonisation. The second allocation period of UK ETS will be delayed by one year in order to align with the launch of UK CBAM in 2027. Businesses will be expected to file their first returns by 31 May 2028, and maintain quarterly records for six years.

UK CBAM will apply to imports of aluminium, cement, fertilisers, hydrogen, iron and steel. Those subject to UK CBAM will be required to submit a CBAM return and pay a fee at the end of each accounting period based on the carbon content of their imports and the UK’s carbon price.

In May 2025, a common understanding issued by the European Commission and the UK indicates that any linking agreement in respect of the EU and UK ETS should create the conditions for goods originating from the EU and UK to benefit from mutual exemptions from the respective UK and EU CBAMs. The final secondary legislation implementing CBAM into English law will be published later this year.

Incentive schemes

Low Carbon Power Incentives – Renewables Obligation/Contracts for Difference

The generation of low carbon power in the UK has historically been subject to a number of incentive schemes regulated by Ofgem and various implementing legislative instruments. For instance, the Renewables Obligation, introduced in 2002, requires electricity suppliers to source a specific proportion of their electricity from renewable sources. This is achieved through requiring UK electricity suppliers to present a certain number of Renewables Obligation certificates (ROCs) to Ofgem in respect of each MWh of electricity they supply to non-exempt customers during an obligation year. 

The Contracts for Difference (CFD) regime replaced the Renewables Obligation (RO) in 2017 as the main support mechanism for new medium to large-scale low carbon energy generation. Between CfD’s introduction and RO’s closure in 2017 for almost all new capacity, projects could choose between the two schemes. Some generators operated under both (a dual scheme), and grace periods were offered for delayed deployments. Qualifying generating stations will continue to be supported under the RO scheme until their accreditation expires. “Early years” generators shall retire from the scheme in 2027.

RO certificates remain unchanged in terms of policy and structure. Accredited renewable generators still receive ROCs, which are traded with electricity suppliers or paid out through a buy-out fund. Existing projects are guaranteed support for 20 years, with payments continuing until projects come off the scheme between 2027 and 2037.

Ofgem is responsible for administering the Contracts for Difference scheme, which incentivises investment in renewable energy by providing developers with price stability through guaranteeing a “strike price”.

Adaptation

The UK increased adaptation spending from GBP0.5b in 2019 to GBP1.5b in 2025.

As part of the COP28 outcome on the global goal on adaptation, UK Government adopted the UAE Framework for Global Climate Resilience. The UK Government published the Third National Adaptation Programme pursuant to the Climate Change Act in July 2023 (NAP3). It specifies the actions that the government will take over the following five years to adapt infrastructure, the natural environment, the built environment, industry and business to the effects of climate change. The most recent Adaptation Communication provided to the UNFCCC by the UK was on 19 October 2021. The focus of the UK’s NDC is on climate change mitigation. Whilst the UK recognises the criticality of climate change adaptation, the UK will submit an updated Adaptation Communication to the UNFCCC in due course. NAP4 is expected to be published in 2028. NAP3 sets out extensive plans to protect, restore and create coastal and marine habitats and manage the risks and opportunities to marine species, habitats and fisheries.

Role of Mitigation and Adaptation in Grant of Environmental Permits

In R (on the application of Finch on behalf of the Weald Action Group) v Surrey County Council and others ([2024] UKSC 20), Horse Hill Developments sought planning permission from Surrey County Council to retain and expand an existing onshore oil well site and to drill four new wells enabling the production of hydrocarbons from six wells over a period of 25 years. The environmental impact assessment considered the environmental impacts of the direct releases of GHGs from within the well site boundary but not the impact of downstream GHGs that would result from the extracted oil subsequently being refined and used as fuel.  The Supreme Court held that the local authority’s decision to grant planning permission without taking the downstream GHGs into account was unlawful. 

In R (Friends of the Earth Ltd and others) v Heathrow Airport Ltd [2020] UKSC 52, the UK Supreme Court overturned the Court of Appeal’s decision that had allowed the judicial review of the UK Airports National Policy Statement. The Supreme Court held that the Paris Agreement and government announcements did not constitute “government policy” for the purposes of the Planning Act 2008 and, as such, the Secretary of State had not breached their duty under the Planning Act 2008 to have regard to the desirability of mitigating and adapting to climate change – ie, by failing to consider the Paris Agreement beyond the extent to which it had already been considered. 

In Friends of the Earth Ltd v Secretary of State for Levelling Up, Housing and Communities [2024] EWHC 2349 (Admin), the High Court ordered the quashing of the 2022 planning permission granted by the Secretary of State for a new underground coal mine at Whitehaven, Cumbria on the basis that the Secretary of State had breached EIA requirements pursuant to the Town and Country Planning Act 1990 by not assessing the impact of GHG emissions from the burning of mined coal (applying the Finch case).

By contrast, in R (on the application of Greenpeace Ltd) v Secretary of State for Energy Security and Net Zero [2023] EWHC 2608 (Admin), the High Court refused applications for judicial review of a decision by DESNZ to launch a new North Sea oil and gas licensing round on the basis that UK Government did not need to take into account Scope 3 GHG emissions when preparing the strategic environmental assessment of its Offshore Energy Plan.

In the past year, the decision of Finch has been further distinguished through subsequent developments in case law. Namely, in R (LADACAN) v SST and Anor [2025] EWHC 3206 (Admin), the High Court dismissed the application for judicial review of Secretary of State’s decision to grant a Development Consent Order for the expansion of London Luton Airport on the basis that “the evaluation of the significance of an estimated amount of GHG emissions and its acceptability is a matter of fact and judgment for the decision-maker. He or she may decide to choose benchmarks to help in arriving at that judgment. But that choice too is a matter of judgment for them”. Such evaluation can be challenged on the basis of Wednesbury unreasonableness, which was not pursued in this case.

See 2.6 Climate Litigation.

Backlash

Reform UK, a right-wing populist political party led by Nigel Farage, won 1,400 new councillor seats in the May 2026 local elections. This has resulted in widespread changes to the pension committees of some of the largest local government pension funds in the UK. Reform has challenged investment strategies based on the net zero agenda and many analysts expect changes to the investment mandates for pension schemes funded by councils now run by Reform. At the time of publication, commentators have noted a shift in Reform’s position, framed increasingly around directing resources toward adaptation and resilience measures rather than opposing net zero outright. Reform has cited the UK’s small share of global emissions as one reason for this shift, while commentators separately note that the reframing may reflect continued British public acceptance of climate science even as support for net zero policies has softened.

In July 2026, Andy Burnham was voted in by Labour MPs as the UK’s new Prime Minister, and while Mr Burnham has demonstrated a commitment to policies underpinned by net zero, he has expressed “something of an open mind” with respect to granting new exploration and production licences for the North Seas. This is widely acknowledged as a pragmatic response to Reform’s deregulatory agenda on net zero, which the GMB union considers instrumental in Reform’s success in the May elections amongst voting workers. At the time of writing, it is anticipated by commentators that approval for the exploration and production from the Rosebank and Jackdaw oil and gas fields are likely to gain approval from a Burnham administration.

The key policy and administrative authorities responsible for climate change policy development are:

• Climate Change Committee (including the Adaptation Sub-Committee);
• The Department for Energy Security and Net Zero (DESNZ);
• Department for Environment, Food & Rural Affairs (DEFRA);
• Department for Business, Energy and Industrial Strategy (BEIS);
• HM Treasury;
• The Environmental Audit Committee of the House of Commons;
• Ofgem; and
• Transition Finance Council.

By virtue of its mandate under the Climate Change Act 2008, the Climate Change Committee holds a high level of influence over UK government on the evolution of climate change policy in the UK. DESNZ holds a significantly larger policy portfolio compared to DEFRA on climate change policy development. BEIS oversees the climate-related financial disclosure regulations applicable to companies and limited liability partnerships enacted pursuant to the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 and the Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022. While the Environmental Audit Committee does not hold executive power, it does have considerable influence in public discourse through its scope which is to examine how government departments’ policies influence the environment and sustainable development. Ofgem is responsible for administering the Contracts for Difference scheme, which incentivises investment in renewable energy by providing developers with price stability through guaranteeing a “strike price”. The Transition Finance Council is a newly created non-departmental public body whose aim is to leverage the UK’s existing strengths to become the best place in the world to credibly raise transition capital.

The key governance and regulatory authorities responsible for regulatory enforcement in respect of climate change regulation are:

• Financial Reporting Council (FRC);
• Financial Conduct Authority (FCA);
• Environment Agency (EA);
• Office for Environmental Protection (OEP); and
• Local authorities.

The FRC is responsible for enforcement of climate-related financial disclosure regulation applicable to AIM and large private companies. The FCA is responsible for oversight and enforcement of the climate-related financial disclosure regulation enshrined in UK listing rules and the ESG Sourcebook applicable to companies listed on the London Stock Exchange and FCA-authorised firms respectively. The EA has oversight of the UK Emissions Trading Scheme, the Environment Act 1990, the Environmental Permitting (England and Wales) Regulations 2016, the Energy Savings Opportunity Scheme 2014 and flooding. The OEP has oversight of the implementation of the Environment Act 2021 which is the UK’s post-Brexit framework for environmental protection. Local authorities support the enforcement of legislation protecting against greenwashing.

Climate change-related litigation has become a new strand of case law in the UK, and can be examined through two lenses: pursuit of private actor defendants and separately, public sector defendants.

The Finch Case

In R (on the application of Finch on behalf of the Weald Action Group) v Surrey County Council and others ([2024] UKSC 20), Horse Hill Developments sought planning permission from Surrey County Council to retain and expand an existing onshore oil well site and to drill four new wells enabling the production of hydrocarbons from six wells over a period of 25 years. The environmental impact assessment considered the environmental impacts of the direct releases of GHGs from within the well site boundary but not the impact of downstream GHGs that would result from the extracted oil subsequently being refined and used as fuel. The Supreme Court held that the local authority’s decision to grant planning permission without taking the downstream GHGs into account was unlawful. 

Friends of the Earth Litigation

The litigation led by Friends of the Earth provides a rich source of evidence of the varying interpretations of role of the Paris Agreement in judicial review of administrative decision-making in recent years.

In R (Friends of the Earth and others) v Secretary of State for BEIS [2022] EWHC 1841 (Admin), the High Court allowed a judicial review challenge to the UK’s October 2021 Net Zero Strategy on the basis that the strategy did not include matters that were material to the issue of whether the targets set under the Climate Change Act 2008 could be met.

Similarly, in R (Friends of the Earth and others) v Secretary of State for Energy Security and Net Zero [2024] EWHC 995 (Admin), the High Court upheld a further judicial review finding that the Secretary of State had failed to comply with their obligations under the Climate Change Act 2008 in relation to their approval of proposals and policies in the UK government’s Carbon Budget Delivery Plan which purported to fill gaps in the Net Zero strategy.

However, in R (Friends of the Earth) v Secretary of State for Environment, Food and Rural Affairs [2024] EWHC 2707 (Admin), the High Court dismissed the application for judicial review of NAP3. Friends of the Earth has indicated that it is applying to the European Court of Human Rights.

In R (Friends of the Earth Ltd and others) v Heathrow Airport Ltd [2020] UKSC 52, the UK Supreme Court overturned the Court of Appeal’s decision that had allowed the judicial review of the UK Airports National Policy Statement. The Supreme Court held that the Paris Agreement and government announcements did not constitute “government policy” for the purposes of the Planning Act 2008 and, as such, the Secretary of State had not breached their duty under the Planning Act 2008 to have regard to the desirability of mitigating and adapting to climate change – ie, by failing to consider the Paris Agreement beyond the extent to which it had already been considered. 

In R (Friends of the Earth Ltd.) v Secretary of State for International Trade/UK Export Finance [2023] EWCA Civ 14, the Court of Appeal dismissed an application for judicial review of a decision by UKEF to provide export finance to a liquified natural gas project in Mozambique. The court confirmed the department should be granted a significant margin of appreciation as it was the first UK government department to assess climate change impacts in the context of a long-term foreign project.

In Friends of the Earth Ltd v Secretary of State for Levelling Up, Housing and Communities [2024] EWHC 2349 (Admin), the High Court ordered the quashing of the 2022 planning permission granted by the Secretary of State for a new underground coal mine at Whitehaven, Cumbria on the basis that the Secretary of State had breached EIA requirements pursuant to the Town and Country Planning Act 1990 by not assessing the impact of GHG emissions from the burning of mined coal (applying the Finch case).

By contrast, in R (on the application of Greenpeace Ltd) v Secretary of State for Energy Security and Net Zero [2023] EWHC 2608 (Admin), the High Court refused applications for judicial review of a decision by DESNZ to launch a new North Sea oil and gas licensing round on the basis that UK government did not need to take into account Scope 3 GHG emissions when preparing the strategic environmental assessment of its Offshore Energy Plan.

In R (LADACAN) v SST and Anor [2025] EWHC 3206 (Admin), the High Court dismissed the application for judicial review of Secretary of State’s decision to grant a Development Consent Order for the expansion of London Luton Airport on the basis that “the evaluation of the significance of an estimated amount of GHG emissions and its acceptability is a matter of fact and judgment for the decision-maker. He or she may decide to choose benchmarks to help in arriving at that judgment. But that choice too is a matter of judgment for them”. Such evaluation can be challenged on the basis of Wednesbury unreasonableness, which was not pursued in this case.

In R (Caffyn) v Shropshire Council, Caffyn, filed an application for judicial review challenging Shropshire Council’s decision to grant planning permission for an intensive poultry unit at a local farm. The facility was expected to generate large volumes of manure, much of which would be treated in an anaerobic digester to produce digestate for use as fertiliser. The claim focused on the adequacy of the environmental impact assessment conducted under the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, and on compliance with the Conservation of Habitats and Species Regulations 2017. The claimant argued, relying on the Supreme Court’s reasoning in R (Finch) v Surrey County Council [2024] UKSC 20, that the Council was required to assess the indirect environmental effects of spreading manure and digestate on farmland and watercourses. Fordham J held that the Council’s approach was unlawful. Although officers had collected information, they failed to make the evaluative judgments required by Finch on causation and on the capability of meaningful assessment of indirect effects. The judge found that processing manure into digestate did not break the causal chain between the IPU and subsequent environmental effects, and that the impacts of digestate – such as nutrient pollution, ammonia emissions, and contributions to climate-relevant air and water quality degradation – were sufficiently connected to the project to require assessment.

In R (Hynot Limited) v Secretary of State for Energy Security and Net Zero (SSESNZ) and another, a group of NGOs brought a judicial review against the decision by the Secretary of State for Energy Security and Net Zero (SSESNZ) to agree to the grant of consent for the “HyNet Carbon Dioxide Transportation and Storage Project – Offshore” (the “Development”), itself part of a larger project involving hydrogen production, transport and storage (the “HyNet Cluster”). The Development comprises three geological gas storage sites in the Liverpool Bay Area beneath the East Irish Sea, and is designed to store 109 million tonnes of carbon dioxide. The claimant also challenged the decision of the Oil and Gas Authority (trading as the North Sea Transition Authority (NSTA)) to grant consent for the Development. The challenge was brought on three grounds:

• ground 1 – failure to assess major accidents and disasters (MAD) effects and/or a failure to carry out a lawful public consultation, as required under the EIA Regulations;
• ground 2 – failure to assess cumulative effects of the Development on climate, as required under the EIA Regulations; and
• ground 3 – failure to comply with the requirements of the Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001.

The Court, on 15 October 2025, refused HyNot’s application for judicial review. It found that: on ground 1, the MAD had been assessed through the EIA process – which EIA legislation “does not impose a standard of perfection”, but rather requires “an adequate basis for public consultation”. On the flooding risk to the terminal, which the claimant had highlighted, the court found that the emergency shut down process which would be in place was “a rational approach”, and that the Secretary of State had made no arguable legal error in relation to it. Moreover, the court found that the Secretary of State had complied with the consultation requirements. On ground 2, the claimant argued that, to fully assess the Development’s environmental effects and its impact on climate, the cumulative effects of the wider HyNet Cluster needed to be assessed. The court disagreed, finding that it had to focus on the specific project, the Development; here, consent wasn’t being sought for a “multi-phase scheme”, and the HyNet Cluster was subject to its own EIA requirements, thus its impacts were not to be taken into account in assessing the Development’s own impacts. Moreover, the CO2 emissions deriving from hydrogen production wouldn’t be indirect, secondary, or cumulative effects of the Development, as a matter of causation. Regarding ground 3, the court held that the Secretary of State had “sufficient information to be satisfied that there would be no adverse effects upon the integrity of any relevant protected site”, therefore “it was rational to conclude further consultation with the public was unnecessary.” Lastly, the court found that the claimant had not acted sufficiently promptly in filing the claim three months after the relevant decision had been made; and would have disallowed the application on this basis. The claimant has stated it has appealed the decision.

The Shell Decision – Section 172 and Section 174 Companies Act

In ClientEarth v Shell plc [2023] EWHC 1897, the High Court dismissed ClientEarth’s derivative claim pursuant to Section 261(1) of the Companies Act 2006 against the board of Shell in its capacity as a shareholder, alleging that Shell’s directors acted in breach of their duties under:

• Section 172 Companies Act 2006 to promote the success of the company for the benefit of its membership as a whole; and
• Section 174 Companies Act 2006, which requires directors to act with reasonable care, skill and diligence because of their failure to develop a robust climate change risk mitigation strategy.

The claim was rejected on the basis that ClientEarth had not brought the case in good faith, and there was no universally accepted methodology as to how Shell might be able to achieve the targeted reductions referred to in its energy transition strategy.

Other Key Causes of Action

UK Prospectus Regulation

In R (Client Earth) v Ithaca Energy Plc [2023] EWHC 3301 (Admin), the High Court refused ClientEarth’s application for permission to apply for judicial review of the FCA’s decision to approve the prospectus of UK oil and gas company, Ithaca Energy plc. The UK Prospectus Regulation did not impose a separate requirement for the issuer to disclose its assessment of risk and materiality.

Misrepresentation Act 1967; Law of Negligence; Misrepresentation

Statutory claims on the basis of the Misrepresentation Act 1967 or civil claims on the basis of the law of negligence or misrepresentation are not yet a significant feature of English law. Nevertheless, these avenues remain open to non-governmental organisations who may be frustrated at the variable outcomes resulting from pursuit of the other causes of action summarised in this chapter.

Product-related claims

We also know that substantial litigation in respect of “greenwashing”, or investigations in respect of misrepresentation of the nature and depth of a company’s “green” credentials, has emerged in the UK in recent years. The Advertising Standards Agency (ASA) has proven to be a prolific enforcer of anti-greenwashing provisions in the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (UK CAP). By way of example, the ASA upheld a series of complaints against HSBC on the basis that it had acted in breach of the UK CAP through a series of advertisements featuring environmental claims that omitted material information in respect of its contribution to carbon dioxide and GHG emissions through other business lines.

Claims may also be brought on the basis of (i) the Business Protection from Misleading Marketing Regulations 2008 and (ii) consumer protection law where a consumer relied on greenwashing claims as part of their purchase of a particular product regulated by the Sale of Goods Act 1979.

Human rights

We are starting to see the emergence of litigation founded on various articles of the European Convention on Human Rights where a claimant has suffered as a result of deteriorating air quality – eg, The King (on the application of Matthew Richards) v EA AC-2025-LON-000626. In that case, the High Court approved an application for judicial review of a failure by the Environment Agency to take over operational responsibility for managing high sulphate was emanating from a landfill site in breach of statutory requirements. The court also granted permission for judicial review on the basis that the EA continues to owe positive obligations under Article 2 (Right to Life) and 8 (Right to a Private Life) of the European Convention on Human Rights, reflecting a broader theme of international climate change litigation founded on human rights arguments.

The UK voluntary carbon market has grown rapidly over the past five years, with growing corporate demand driving an increase in the cost of offsets and support services. Two example regimes in the UK are the Woodland Carbon Code (the largest carbon standard in the UK, with over 1500 registered projects) and the Peatland Code, which have their own registries. In addition, the London Stock Exchange’s Voluntary Carbon Market designation was launched in 2022 to identify funds and operating companies admitted to the Main Market or AIM which are investing in climate change mitigation activities such as carbon sequestration, clean energy and new climate technologies.

See 2.3 National Legal Regime (Command and control measures); 2.3 National Legal Regime (Incentive schemes).

Voluntary carbon units cannot currently be used for compliance in the UK ETS. However, the UK is actively reforming this structure. The UK ETS Authority has announced legislation to integrate high-integrity Greenhouse Gas Removals (GGRs) into the compliance scheme. This will allow certain certified removal units to be sold directly into the ETS from 2029.

Voluntary carbon market-related information is publicly available:

• Supply and Demand in the UK Voluntary Carbon Market July 2022;
• Voluntary carbon and nature markets: raising integrity – consultation document; and
• Voluntary Carbon Market – London Stock Exchange.

The WTO General Agreement on Tariffs and Trade (GATT), which covers trade in goods, aims to reduce barriers to trade such as tariffs, quotas and other restrictions. It sets rules for non-discriminatory trade practices between countries to ensure that domestic and imported goods are treated similarly.

The GATT principle of “national treatment” prohibits discrimination against imports compared with equivalent domestic products. For example, applying an emissions charge on imported steel could be problematic if combined with issuing free carbon allowances to domestic steel producers. The “Most Favoured Nation” (MFN) principle, which is central to the rules-based trading system supported by the GATT, prohibits WTO members from treating equivalent imports differently depending on their country of origin, for example by applying different emissions levies to the same type of cement or steel when imported from different countries. Exemptions to the MFN principle are permitted for goods from countries with a free trade agreement and from developing countries.

Under the GATT, countries also agree to a maximum (“bound”) tariff for each imported product. For goods, these bindings refer to ceilings on customs tariff rates. If a CBAM were designed as a customs duty, any additional tariff could therefore exceed this agreed maximum. Generally, countries can change national tariff bindings, but only if other WTO members agree to it. If no agreement is reached, it could lead to a legal challenge at the WTO. GATT also bans restrictions on trade “other than duties, taxes or other charges”, for example import quotas, import or export licences or other measures. Offering domestic producers an export rebate or a subsidy compensating for their domestic carbon costs could be challenged under the WTO’s Agreement on Subsidies and Countervailing Measures (ASCM).

Authors argue that a CBAM could avoid breaching the principle of national treatment and meet the “level playing field” requirement if applied as an import charge equivalent to an internal tax paid by domestic producers on a similar domestic product or input. The tax should also avoid discriminating against imports or different sources of imports. However, if found in breach, it could possibly be justified on environmental grounds.

Where a measure is nonetheless found to be inconsistent with core principles, it may be justified under GATT health and environmental exceptions. For this, it has to be demonstrated that a measure is: “necessary to protect human, animal or plant life or health” or related to the conservation of exhaustible natural resources and “made effective in conjunction with restrictions on domestic production or consumption”, and does not discriminate arbitrarily between countries in similar conditions or can be seen as a disguised restriction on international trade.

CBAM should be developed primarily as a climate measure aimed at reducing emissions, and the carbon price applied to imports should not exceed the price paid by domestic producers.

See 2.3 National Legal Regime – UK Carbon Border Adjustment Mechanism, for more detail on how the UK is co-ordinating or seeking to align the development of domestic carbon pricing measures with measures or initiatives in other jurisdictions.

Longstanding Disclosure Regimes

Since 2013, companies in scope of annual reporting requirements under the Companies Act 2006 have been required to publish details of their carbon footprint and carbon intensity of operations. The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 and the Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022 amended these provisions to place requirements on certain publicly listed companies, large private companies and LLPs to publish disclosures pursuant to the Task Force on Climate-related Financial Disclosures (TCFD) in addition to carbon footprinting data across Scope 1, 2 and 3 GHG emissions.

The long-standing compliance regime in respect of energy efficiency in the UK is the Energy Savings Opportunity Scheme, which emerged in 2014 as the implementing legislation for the EU Energy Efficiency Directive. It requires in-scope entities to assess energy savings opportunities across their in-scope group and submit a declaration to the EA when this has been completed.

The UK led the world on climate-related financial disclosures for listed entities when it introduced changes to the UK Listing Rules in 2020 to require premium listed entities to report against the TCFD. In 2021, these disclosure requirements were extended to standard listed entities and the UK subsequently committed to mandate TCFD-aligned disclosures across the UK economy by 2025.

FCA ESG Sourcebook and Sustainability Disclosure Requirements

The UK took the step of mandating TCFD-aligned disclosures for in-scope FCA-authorised firms from December 2021 in the new ESG Sourcebook, which forms part of the FCA Handbook for regulated firms. This was followed by the publication of the UK Sustainability Disclosure Requirements by the FCA in November 2023 (SDR), which sought to regulate misleading claims about sustainability and require detailed disclosures by FCA-regulated firms in respect of financial products marketed on the basis of sustainability.

UK SRS is the UK’s sustainability disclosure framework, published on 25 February 2026. Compliance becomes binding through the FCA: under CP26/5, in-scope listed companies would report against UK SRS S2 climate from accounting periods beginning 1 January 2027, with Scope 3 and wider UK SRS S1 topics phased in on comply-or-explain. UK SRS S1 and S2 mirrors IFRS S1 and S2.

UK SRS compliance is currently voluntary. Under FCA CP26/5, approximately 515 listed companies would be required to report against UK SRS S2 climate disclosures for accounting periods beginning 1 January 2027. Scope 3 emissions follow on comply-or-explain from 1 January 2028, with broader S1 sustainability disclosures from 1 January 2029. Large private companies are not yet in scope but the Government is expected to consult through Modernising Corporate Reporting (MCR). The MCR programme is expected to consult on extending UK SRS requirements to private companies following existing Streamlined Energy and Carbon Reporting thresholds (ie companies with 500+ employees or GBP500m+ turnover).

The UK SRS requires disclosure in respect of governance, risk management, strategy and metrics and targets. For UK SRS S2, Scope 1, 2 and 3 GHG emissions must be measured in accordance with the GHG Protocol Corporate Standard. The FRC will oversee preparers’ compliance and has published detailed FAQ guidance on sustainability reporting developments.

Transition Finance Market Review

In April 2022, UK Government launched the Transition Plan Taskforce to develop a framework to help companies develop and communicate their plan to achieve net zero to their stakeholders. The Taskforce subsequently published the Transition Plan Taskforce Disclosure Framework. DESNZ published a consultation in June 2025 on implementation routes for the Transition Plan Taskforce Disclosure Framework, however a proposal for mandatory transition plan disclosures is yet to materialise.

See 2.6 Climate Litigation (The Shell decision – Section 172 and Section 174 Companies Act). In the decision of McGaughey v Universities Superannuation Scheme Ltd [2023], the Court of Appeal held that derivative claims on behalf of a pension trustee company against certain directors and former directors were dismissed on the basis that the derivative claim procedure which founded the claim that the directors had breached their general duties by failing to plan for fossil fuel divestments was available only in exceptional circumstances.

As a technical matter under English law, it is possible for shareholders or a parent company to be held liability in respect of damages caused by climate change and/or breaches of climate change regulation. The two most recent authorities which would underpin this scenario under English law are (i) Vedanta Resources plc and another v Lungowe & others [2019] and Okpabi and others v Royal Dutch Shell plc [2021]. In the Vedanta case, 1826 Zambian residents brought a claim against Vedanta, a UK incorporated parent company and its subsidiary, Konkola Copper Mines plc, which was incorporated in Zambia, for personal injury, loss and damage caused by the discharge of waste from a cooper mine. The Supreme Court held that there was sufficient evidence to establish a triable case against Vedanta on the issue of whether Vedanta owed a duty of care to the Zambian residents. This decision was based on the established general principles for liability under tort law, and was determined through examining the high level of control exerted by Vedanta over Konkola Copper Mines plc evidenced in part through the group-wide environmental policies and procedures through which Vedanta exercised such control.

Similarly, in Okpabi, a group of Nigerian residents living in an area impacted by leaks from pipelines and infrastructure operated by the Shell Petroleum Development Company of Nigeria alleged that the spills had caused damage in breach of the duties of care owed by the subsidiary and parent company. The Supreme Court again permitted the claims to be heard before the English courts on the basis that there was sufficient evidence of control exercised by the parent company over the subsidiary to raise a triable issue of whether there was a duty of care owed by the parent company to the Nigerian residents. Four related claims are now pending before the English courts.

Finally, in Municipio de Mariana v BHP, BHP was held strictly liable as polluter under the Brazilian Environmental Law in November 2025 in respect of the collapse of the Samarco dam. The municipalities had standing to bring proceedings in the UK. BHP exercised control over Samarco's activities, including its short and long-term strategy, investments, production, financial and technical risk assessment and management through the audit process, funding arrangements and the payment of dividends. The 2025 decision held that controlling shareholder power could be used at a more granular level in respect of the detailed business decisions and operations of the company. Exertion of such authority could give rise to responsibility for the activities of the company. The 2026 decision held that the appeal on behalf of BHP has no real prospect of success and there is no other compelling reason for the appeal to be heard.

In practice, however, it is not likely that a parent company could be held liable for damages caused by the contribution of a subsidiary to climate change as we do not yet have a court decision which holds a parent company liable in respect of any such fact pattern.

Surveys conducted of the British public by More in Common and Climate Outreach indicate that in 2024, 36% of the population believed that achieving net zero will be good for the UK, 4% considered it will be very bad for the UK and 26% considered it will be very good for the UK. The numbers shifted slightly in 2025, with the same poll showing that 30% considered achieving net zero to be good for the UK, 9% considered it will be very bad for the UK and 18% considered it will be very good for the UK.

Concern about the impact of climate change remains robust, albeit is proportionate to the level of income of the individual polled. A greater proportion of individuals who cannot afford costs and often have to forego food and heating do not think about climate change; nevertheless, 60% of these individuals worry about the impact of climate change.

YouGov polls from the past five years clearly show that between 60 and 70% of the population do not consider climate change to be exaggerated by scientists.

A YouGov poll conducted in summer 2026 indicated that 70% of the British public considered it likely that the recent heat waves have been caused by climate change.

Please see 2.3 National Legal Regime for details of the pressure being exerted by the Reform Party on social discourse regarding climate change.

Most climate change due diligence conducted on M&A, finance and property jurisdictions in the UK remains limited in nature. This is in part because diligence of sustainability risks (include those arising out of or in connection with climate change) is not a mandatory legal requirement, unlike under the law of the European Union.

See 2.3 National Legal Regime (Incentive schemes). In addition, the Planning and Infrastructure Act 2025 increases the amount of electricity produced from renewable sources by permitting the use of forestry land for such purposes. The Act also provides for strategic planning to be conducted through spatial development strategies which will seek to improve climate resilience. The Act also seeks to ensure that development corporations (ie, statutory bodies established for urban development and regeneration) have due regard to sustainable development and climate change mitigation and adaptation.

CCUS

In the UK, seven major industrial clusters are responsible for 50% of all industry emissions:

• The Black Country;
• Grangemouth;
• Humberside;
• Merseyside;
• Southampton;
• South Wales; and
• Teesside.

The government has prioritised CCUS development in these clusters to achieve high-impact emissions reductions. DESNZ is using a two-track process to allocate support for developing CCUS projects in these clusters (known as cluster sequencing). In October 2021, the government selected HyNet (in north-west England and north Wales) and the East Coast Cluster (ECC) (Humberside and Teesside) as the track one clusters, targeting operation by the mid-2020s. In October 2024, the government announced it had made GBP21.7 billion available over 25 years to support development of the track one clusters. In July 2023, DESNZ announced that the Acorn project (in north-east Scotland) and Viking project (in the Humber) have been chosen as the third and fourth CCUS clusters, targeting operation by 2030.

The government intends the UK CCUS sector to transition to a self-sustaining, industry-led sector that requires little government intervention. The market transition will happen in three stages:

• market creation (storing 20 to 30 Mt per year of CO2 by 2030);
• market transition (the emergence of a commercial and competitive market up to around 2035); and
• a self-sustaining CCUS market (from around 2035 onwards).

GGRs

The government hopes to develop a sustainable market in which engineered GGRs are funded by polluting industries to compensate for their residual emissions. While the market is still at an early stage of development, revenue support is likely to be needed to overcome barriers to investment and incentivise large-scale deployment of the relevant technologies (particularly DACCS and BECCS). To achieve this, the government is developing the GGR business model. The model is based on the CFD scheme for renewable electricity.

The GGR business model will use a 15-year private law contract (GGR contract) between the GGR developer and a government counterparty (likely the Low Carbon Contracts Company (LCCC)). Projects will receive a price guarantee for qualifying GGR credits (a strike price), which reflects the cost of removing one tonne of CO2. The strike price will cover eligible operational expenses and repayment of capital expenditure plus a rate of return on capital investment.

The project will be paid a subsidy for qualifying GGR credits sold on the voluntary carbon market or permitted compliance markets, based on the difference between the strike price and the market value of GGR credits (the reference price). If the strike price exceeds the reference price, the counterparty will pay the difference to the GGR developer. The GGR developer must pay the difference to the counterparty if the reference price exceeds the strike price.