The Impact of ESG on the European Leveraged Finance Markets

In a presidential memorandum issued January 7, President Trump announced the United States will begin executive proceedings to withdraw from a historic number of international organizations, conventions and treaties, including the United Nations Framework Convention on Climate Change and others aimed at environmental protection and climate action.

On December 1, 2025, the New York Department of Environmental Conservation (NYDEC) finalized regulations for its greenhouse gas (GHG) emissions reporting program under the Climate Leadership and Community Protection Act (CLCPA).¹ These rules establish mandatory annual GHG reporting requirements for certain facilities and suppliers beginning June 1, 2027, with earlier compliance milestones for Large Emission Sources and anaerobic digestion, liquid waste storage and certain solid waste landfill operators taking effect in late 2026. We previously wrote about the draft regulations here.

On January 9, 2026, the Ninth Circuit heard oral argument in an appeal challenging California’s climate reporting laws: SB 253 (emissions disclosure) and SB 261 (climate‑related financial risk reporting).¹ The court previously stayed enforcement of SB 261 pending appeal, leaving SB 253 in place for now. We have covered the procedural background leading to oral argument here.

The 30th United Nations Climate Change Conference (COP30) ended on November 22, 2025. Among other things, the package of decisions reflected in the Belém Political Package brings renewed focus on scaling up climate finance and accelerating implementation of the Paris Agreement. The event sharpened focus on implementation and finance rather than binding global commitments. Key issues emerging out of COP30 include: