Climate Change Regulation 2026

UK Law and Practice Contributed by: Ruth Knox and Julian Wolfgramm-King, Paul Hastings LLP

5. Transactions 5.1 Due Diligence

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 com - pany 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. 4.4 Social Context 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% consid - ered 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 individu - als 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 sci - entists. 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 dili - gence of sustainability risks (include those arising out of or in connection with climate change) is not a man - datory legal requirement, unlike under the law of the European Union. 6. Climate-Friendly Investment Support 6.1 Renewable Energy 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 estab - lished for urban development and regeneration) have due regard to sustainable development and climate change mitigation and adaptation. 6.2 Other Support CCUS In the UK, seven major industrial clusters are respon - sible 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 Octo - ber 2021, the government selected HyNet (in north- west England and north Wales) and the East Coast

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