STP COMPLIANCE EHS REGALERT ROUND-UP
May 8th 2026
EU Omnibus Package Dials Back Sustainability Reporting and Supply Chain Programs
On February 26, 2026, the EU Commission published the much-anticipated Omnibus Simplification Package (
Directive (EU) 2026/470). The updates amend four EU directives to simplify and streamline the regulatory framework to reduce the burdens resulting from the Corporate Sustainability Reporting Directive (CSRD) (
Directive 2006/43/EC) and the Corporate Sustainability Due Diligence Directive (CSDDD)
(
Directive 2024/1760). The amendments took effect on March 18, 2026, and Member States have until March 19, 2027, and July 26, 2028, respectively, to transpose the revisions into their national regulations.
On February 26, 2026, the EU Commission published the much-anticipated Omnibus Simplification Package (
Directive (EU) 2026/470). The updates amend four EU directives to simplify and streamline the regulatory framework to reduce the burdens resulting from the Corporate Sustainability Reporting Directive (CSRD) (
Directive 2006/43/EC) and the Corporate Sustainability Due Diligence Directive (CSDDD)
(
Directive 2024/1760). The amendments took effect on March 18, 2026, and Member States have until March 19, 2027, and July 26, 2028, respectively, to transpose the revisions into their national regulations.
With respect to the CSRD amendments, the applicability thresholds for employee size and revenue have been increased to 1,000 average employees and annual net turnover of €450 million for EU-based companies. In terms of reporting requirements, the mandatory data points under the European Sustainability Reporting Standards (ESRS) have been reduced by over 60%. Voluntary disclosures and sector-specific standards have been canceled entirely.
With respect to the CSDDD amendments, similar scope amendments substantially reduce the number of companies subject to the directive, for both EU and non-EU companies. Supply chain monitoring (i.e., audit) requirements have been reduced to a five-year
minimum or after a significant change occurs, and there are reasonable grounds to believe existing measures are no longer adequate. Other noteworthy changes include the removal of legal obligations to implement climate
change transition plans, and penalties are capped at 3% of worldwide turnover.
Given the significant narrowing of scope and reporting requirements, companies should assess if they are still subject to these sustainability programs and review how the changes impact their sustainability and supply chain monitoring programs. Given the global expansion of the International Sustainability Standards Board (ISBB) aligned reporting regulations, companies with a global footprint should strategically consider a consolidated global approach to managing their reporting and due diligence compliance programs.
With respect to the CSRD amendments, the applicability thresholds for employee size and revenue have been increased to 1,000 average employees and annual net turnover of €450 million for EU-based companies. In terms of reporting requirements, the mandatory data points under the European Sustainability Reporting Standards (ESRS) have been reduced by over 60%. Voluntary disclosures and sector-specific standards have been canceled entirely.
With respect to the CSDDD amendments, similar scope amendments substantially reduce the number of companies subject to the directive, for both EU and non-EU companies. Supply chain monitoring (i.e., audit) requirements have been reduced to a five-year
minimum or after a significant change occurs, and there are reasonable grounds to
believe existing measures are no longer adequate. Other noteworthy changes include the removal of legal obligations to implement climate change transition plans, and penalties are capped at 3% of worldwide turnover.
Given the significant narrowing of scope and reporting requirements, companies should assess if they are still subject to these sustainability programs and review how the changes impact their sustainability and supply chain monitoring programs. Given the global expansion of the International Sustainability Standards Board (ISBB) aligned reporting regulations, companies with a global footprint should strategically consider a consolidated global approach to managing their reporting and due diligence compliance programs.
New ISO 14001:2026 – EMS Standard Released
On April 15, 2026, ISO released the final amendments to ISO 14001, its environmental management system (EMS) standard. It cancels and replaces the 2015 version. Organizations certified under ISO:2015 have three years to certify to the revised standard.
While no entirely new requirements are introduced, the 2026 revisions expand existing concepts, update key terminology, and better align 14001 with other ISO management system standards.
Many expanded concepts and clarifications formalize considerations that were merely implied in the 2015 version. Life cycle perspective considerations are now a mandated component of the EMS (Clause 4.3). Also, “externally provided processes, products and services” (Clause 8.1) replaces “outsourced processes.” In fact, the term “outsource” is gone completely from version 2026. Better harmonization between standards can be seen in several places,
such as a new clause, 6.3, matches an ISO 19011 clause, and a new internal audit requirement
On April 15, 2026, ISO released the final amendments to ISO 14001, its environmental management system (EMS) standard. It cancels and replaces the 2015 version. Organizations certified under ISO:2015 have three years to certify to the revised standard.
While no entirely new requirements are introduced, the 2026 revisions expand existing concepts, update key terminology, and better align 14001 with other ISO management system standards.
Many expanded concepts and clarifications formalize considerations that were merely implied in the 2015 version. Life cycle perspective considerations are now a mandated component of the EMS (Clause 4.3). Also, “externally provided processes, products and services” (Clause 8.1) replaces “outsourced processes.” In fact, the term “outsource” is gone completely from version 2026. Better harmonization between standards can be seen in several places,
such as a new clause, 6.3, matching an ISO 19011 clause, and a new internal audit requirement to define objectives, a 19011 best practice.
In practice, these changes mean expanding controls over externally provided processes, products, and services relevant to the EMS. That could include actively tracking suppliers’ practices and incorporating product use data into information systems. Other enhanced requirements help organizations assess how environmental conditions, including natural resource availability, climate change, and biodiversity, affect their operations and how their activities impact the environment. This broadened, more outward-looking shift runs throughout the new version.
Companies should conduct a gap analysis now that the final version is available and develop a transition plan to ensure policies, procedures, and training are in place to maintain certification with the revised standard. In a related note, a review of ISO 45001:2018 – Occupational Health and Safety Management System – has been initiated, with a published version expected in 2027.
to define objectives, a 19011 best practice.
In practice, these changes mean expanding controls over externally provided processes, products, and services relevant to the EMS. That could include actively tracking suppliers’ practices and incorporating product use data into information systems. Other enhanced requirements help organizations assess how environmental conditions, including natural resource availability, climate change, and biodiversity, affect their operations and how their activities impact the environment. This broadened, more outward-looking shift runs throughout the new version.
Companies should conduct a gap analysis now that the final version is available and develop a transition plan to ensure policies, procedures, and training are in place to maintain certification with the revised standard. In a related note, a review of ISO 45001:2018 – Occupational Health and Safety Management System – has been initiated, with a published version expected in 2027.
Rescission of the U.S. EPA’s Endangerment Finding
In a major policy reversal, the federal EPA rescinded its 2009 administrative rule, the Endangerment Finding, effective April 20, 2026. The 2009 rule concluded that six key greenhouse gases: carbon dioxide, methane, nitrous oxide, hydro- and per- fluorocarbons, and sulfur hexafluoride, are a danger to public health and welfare. EPA made the rule because the Supreme Court ruled against it in a 2006 case following the EPA’s denial of state petitions to regulate vehicle emissions as instructed under section 201(b) of the Clean Air Act.
The immediate effect is the elimination of the legal basis for federal GHG standards for new light-, medium-, and heavy-duty vehicles. Other programs that are similarly exposed are the greenhouse gas emission standards for fossil fuel
In a major policy reversal, the federal EPA rescinded its 2009 administrative rule, the Endangerment Finding, effective April 20, 2026. The 2009 rule concluded that six key greenhouse gases: carbon dioxide, methane, nitrous oxide, hydro- and per- fluorocarbons, and sulfur hexafluoride, are a danger to public health and welfare. EPA made the rule because the Supreme Court ruled against it in a 2006 case following the EPA’s denial of state petitions to regulate vehicle emissions as instructed under section 201(b) of the Clean Air Act.
The immediate effect is the elimination of the legal basis for federal GHG standards for new light-, medium-, and heavy-duty vehicles. Other programs that are similarly exposed are the greenhouse gas emission standards for fossil fuel power generation facilities,
for which the proposed rescission is more certain, and the Methane Emissions Reduction Program (MERP). MERP includes over $1B in remaining Inflation Reduction Act funding for monitoring, measuring, and reducing
methane emissions, as well as the Waste Emissions Charge rule of 2024, the effectuation of which is currently delayed by Congressional resolution. New regulatory action to control greenhouse gases from
industrial sources, specifically those aimed at addressing climate change, is effectively barred.
Litigation is certain. Petitions for review were required to be filed within 60 days of the publication in the Federal Register. Within that period, over two dozen states, 10 cities, and environmental groups filed suits challenging it in the US Court of Appeals for the DC Circuit.
power generation facilities, for which the proposed rescission is more certain, and the Methane Emissions Reduction Program (MERP). MERP includes over $1B in remaining Inflation Reduction Act funding for monitoring, measuring, and reducing methane emissions, as well as the Waste Emissions Charge rule of 2024, the effectuation of which is currently delayed by Congressional resolution. New regulatory action to control greenhouse gases from industrial sources, specifically those aimed at addressing climate change, is effectively barred.
Litigation is certain. Petitions for review were required to be filed within 60 days of the publication in the Federal Register. Within that period, over two dozen states, 10 cities, and environmental groups filed suits challenging it in the US Court of Appeals for the DC Circuit.
Site Remediation Changes in New York
On December 31, 2025, the New York State Department of Environmental Conservation (DEC) adopted, with immediate effect,
comprehensive amendments to the state’s environmental remediation regulations at 6 NYCRR Part 375. The action implements the 2015 and 2022 statutory amendments that materially affect eligibility for the Brownfield Cleanup Program (BCP). Other revisions, originating from DEC, significantly affect remedial procedures.
As a change to the BCP cleanup track provisions, DEC will issue Track 1 Certificates of Completion (CoC) only after groundwater has reached asymptotic levels.
On December 31, 2025, the New York State Department of Environmental Conservation (DEC) adopted, with immediate effect,
comprehensive amendments to the state’s environmental remediation regulations at 6 NYCRR Part 375. The action implements the 2015 and 2022 statutory amendments that materially affect eligibility for the Brownfield Cleanup Program (BCP). Other revisions, originating from DEC, significantly affect remedial procedures.
As a change to the BCP cleanup track provisions, DEC will issue Track 1 Certificates of Completion (CoC) only after groundwater has reached asymptotic levels.
DEC will issue Track 2 CoC for sites that achieve the soil remedy to unrestricted use while short-term institutional or engineering controls remain to manage residual groundwater and soil vapor. If those remedies are achieved within
five years, DEC will accept petitions for a modified Track 1 CoC.
Amendments to soil cleanup objectives (SCOs) are another notable example. The majority of SCOs are based on revised factors, including reference doses, partitioning coefficients, and exposure calculations. Two new chemicals, aniline and nitrobenzene, are added, and DEC states that per- and polyfluoroalkyl substances (PFAS) SCOs are forthcoming.
DEC will issue Track 2 CoC for sites that achieve the soil remedy to unrestricted use while short-term institutional or engineering controls remain to manage residual groundwater and soil vapor. If those remedies are achieved within five years, DEC will accept petitions for a modified Track 1 CoC.
Amendments to soil cleanup objectives (SCOs) are another notable example. The majority of SCOs are based on revised factors, including reference doses, partitioning coefficients, and exposure calculations. Two new chemicals, aniline and nitrobenzene, are added, and DEC states that per- and polyfluoroalkyl substances (PFAS) SCOs are forthcoming.
Ontario Adopts CSA Fuel Oil Code Revisions for Owners of Oil-Burning Equipment
On April 2, 2026, the Technical Standards & Safety Association released its
Fuel Oil Code Adoption Document (CAD), adopting the Canadian Standards Association Standard, CSA B139:24 (series 24) “Installation Code for Oil Burning Equipment,” with Ontario-specific amendments, effective June 2, 2026. The CAD is issued under the Technical Standards and Safety Act, 2000, and Ontario Regulation 223/01 (Codes and Standards Adopted by Reference) and 213/01 (Fuel Oil). Published in January 2024, this Standard includes requirements for the installation and alteration of stationary and portable oil-burning equipment, ancillary equipment, maintenance, and tank filling. It is particularly noteworthy that fuel storage tanks attached to emergency generators are subject to many of the requirements in this Standard series, which is divided into the following:
- – CSA B139.1.0:24 – General requirements for large installations (e.g., large oil-burning equipment)
- – CSA B139.1.1:24 – General requirements for stationary engines (e.g., oil-fueled stationary engines used for the generation of electricity);
On April 2, 2026, the Technical Standards & Safety Association released its
Fuel Oil Code Adoption Document (CAD), adopting the Canadian Standards Association Standard, CSA B139:24 (series 24) “Installation Code for Oil Burning Equipment,” with Ontario-specific amendments, effective June 2, 2026. The CAD is issued under the Technical Standards and Safety Act, 2000, and Ontario Regulation 223/01 (Codes and Standards Adopted by Reference) and 213/01 (Fuel Oil). Published in January 2024, this Standard includes requirements for the installation and alteration of stationary and portable oil-burning equipment, ancillary equipment, maintenance, and tank filling. It is particularly noteworthy that fuel storage tanks attached to emergency generators are subject to many of the requirements in this Standard series, which is divided into the following:
– CSA B139.1.0:24 – General requirements for large installations (e.g., large oil-burning equipment)
– CSA B139.1.1:24 – General requirements for stationary engines (e.g., oil-fueled stationary engines used for the generation of electricity);
– CSA B139.1.2:24 – General requirements for special installations (e.g., central oil distribution systems; construction heaters and fuel systems)
– CSA B139.2:24 – Installation code for oil-burning equipment for small commercial buildings.
Key Province-specific amendments include Annex K, on Operational practices for environmental protection (e.g., leak, spill response); required engineering calculations for underground tanks entirely or partially installed below the top elevation of the water table (Amendment 1.1.13); variations in the size of combustion air openings in certain equipment when special engineering methods are used (Amendment 1.1.15); and the extension of the timeframe for the approval of portable oil-burning equipment to December 1, 2030, with inspection requirements (Amendment 1.2.1).
Other CADs published in April 2026 in an effort to harmonize Ontario code requirements with other jurisdictions include the
2026 Propane CAD, adopting new requirements approved by CSA B149.1, CSA B149.2, CSA B149.3, and CSA B149.5, and the
2026 Gaseous Fuels CAD, adopting CSA B149.1, CSA B149.3, and CSA B149.6, all published in 2025, among other standards.
– CSA B139.1.2:24 – General requirements for special installations (e.g., central oil distribution systems; construction heaters and fuel systems)
– CSA B139.2:24 – Installation code for oil-burning equipment for small commercial buildings.
Key Province-specific amendments include Annex K, on Operational practices for environmental protection (e.g., leak, spill response); required engineering calculations for underground tanks entirely or partially installed below the top elevation of the water table (Amendment 1.1.13); variations in the size of combustion air openings in certain equipment when special engineering methods are used (Amendment 1.1.15); and the extension of the timeframe for the approval of portable oil-burning equipment to December 1, 2030, with inspection requirements (Amendment 1.2.1).
Other CADs published in April 2026 in an effort to harmonize Ontario code requirements with other jurisdictions include the
2026 Propane CAD, adopting new requirements approved by CSA B149.1, CSA B149.2, CSA B149.3, and CSA B149.5, and the
2026 Gaseous Fuels CAD, adopting CSA B149.1, CSA B149.3, and CSA B149.6, all published in 2025, among other standards.
