Environment | UK Regulatory Outlook May 2025

UK Woodland Carbon Code publishes template agreements for purchasing carbon units

The UK Woodland Carbon Code team at Scottish Forestry and the UK Peatland Programme have collaborated to create template agreements for the purchase and sale of Pending Issuance Units (PIUS) and Carbon Units (CUs) from peatland and woodland projects.

These agreements are publicly accessible for use across the UK, with versions specifically tailored to each of the UK's legal jurisdictions. Their purpose is to foster market development and instil confidence among buyers and sellers. However, it is not mandatory to use these templates for Peatland Code or Woodland Carbon Code projects.

A link to the template agreements can be found on the Woodland Carbon Code website and further information is available within this short video.

UK government consults on implementation of principles for voluntary carbon and nature market integrity

The government has opened a consultation inviting feedback on the implementation of its principles for the voluntary markets where carbon and other credits are produced and purchased (excluding the UK Emission Trading Scheme).The six principles originally published by the Department for Energy Security and Net Zero (DESNZ) in November 2024 are:

• Use credit in addition to ambitious actions within value chain.
• Use high integrity credit.
• Measure and disclose the planning use of credits as part of sustainability reporting.
• Plan ahead.
• Make accurate green claims using appropriate terminology.
• Co-operate with others to support the growth of high integrity markets.

The consultation aims to ensure that interventions across government and the private sector create a cohesive regime for unlocking capital, whilst also clarifying regulatory responsibilities. The government will introduce these principles in a proportionate manner with the aim of aligning common processes across markets, while simultaneously acknowledging the varying maturity, scale and characteristics of different projects.

The consultation closes on 10 July 2025.

HM Treasury consults on reform of Landfill Tax

The government has invited feedback on proposed reforms of Landfill Tax in England and Northern Ireland. This follows calls for evidence on reform by the previous government at the end of 2021. The government response to these calls for evidence was published in 2023 and concluded that the current approach of applying Landfill Tax rates based on material type is outdated and does not fully align with modern waste processes.

The consultation seeks views on the following proposed changes:

• Transitioning to a single rate of Landfill Tax by 2030.
• Removing the Qualifying Fines Regime from April 2027.
• Removing the exemption for filling quarries from 2027.
• Removing the exemption for stabilisers used in dredged material from April 2027.
• Removing the water discounting scheme from April 2027.
• Increasing the rate applied to disposals at unauthorised waste sites.

The consultation closes on 21 July 2025.

Environment Principles, Governance and Biodiversity Targets (Wales) Bill announced for introduction before summer 2025

Following the Welsh government's response in January 2024 to its consultation "Securing a Sustainable Future Environmental Principles, Governance and Biodiversity targets for a Greener Wales,” minister for delivery, Julie James, announced that the Environment Principles, Governance and Biodiversity Targets (Wales) Bill will be introduced to the Senedd before the 2025 summer recess.

As outlined in the consultation response, the bill will seek to:

• incorporate environmental principles into Welsh law, emphasising a high level of environmental protection and promoting sustainable development;
• introduce environmental governance within Welsh law, featuring an independent body responsible for enforcing environmental regulations against public entities and
• establish biodiversity targets and obligations in Wales, aiming to reverse the decline of nature by 2030 and pursue a nature-positive agenda.

Read the full oral statement by Julie James.

Code of Practice launched for Scope 3 greenhouse gas emissions by the Voluntary Carbon Markets Integrity Initiative

The Voluntary Carbon Markets Integrity Initiative (VCMII) has published a Code of Practice for Scope 3 greenhouse gas emissions (GHG). Traditionally the hardest GHG emissions for businesses to reduce, occurring across a company's value chain (for example GHG emissions associated with the production of purchased material), the VCMII's Code of Practice aims to produce a "practical, high integrity solution".

The code provides:

• A practical step-by-step framework to help companies realise their Scope 3 decarbonisation targets;
• Strict guardrails to ensure the use of carbon credits is a temporary, transparent and accountable measure and not a substitute for decarbonisation;
• Clear disclosure requirements for companies to report their emissions gap and actions needed to help realise their net zero goals.

A further press release from the VCMII can be found here.

Climate Change Committee publishes 2025 progress report to Parliament

The Climate Change Committee has published its 2025 progress report on the government's adaptation to climate change. The report reviews its Third National Adaptation Programme (NAP3) and its implementation. In short, the report summarises that:

• The UK's preparations for climate change are inadequate.
• The government has yet to change the UK's inadequate approach to tackling climate risks.
• The government must act without further delay to improve the national approach to climate resilience.

Among the most pressing risks that will reach an unacceptable level and require the proactive adaption now are: (1) increasing threats to food production by extreme weather; (2) an increasing number of properties at risk of flooding or overheating; (3) future heat posing a risk to the health and lives of vulnerable people; and (4) extreme weather more frequently disrupting key infrastructure.

The report concludes with recommendations that the government's NAP3:

• Improves objectives and targets.
• Improves co-ordination across government and integrate wider resilience efforts.
• Integrates adaptation into all relevant policies.
• Implements monitoring, data collection, reporting and evaluation across all sectors.

Government announces rapid review of local authority enforcement of fly-tipping waste offences

The government has announced a review of local authority enforcement of fly-tipping waste offences. It has indicated that the changes it is considering include:

• Using drones and mobile CCTV cameras to identify vehicles used for fly-tipping.
• Requiring fly-tippers to pay the costs of seizing and storing fly-tipping vehicles, instead of this being a cost for local authorities.
• Increasing the types of waste offences that could incur a five-year prison sentence.

The government is also considering giving the principal regulator, the Environment Agency, powers to carry out identity and criminal record checks on waste operators and increased powers to fund enforcement costs through environmental permits, revoke permits and issue enforcement notices and fines.

Planning and Infrastructure Bill moves to committee stage in House of Commons

On 11 March 2025, the Planning and Infrastructure Bill received its first reading in the House of Commons. It passed its second reading in the House of Commons on 24 March, and moved on to its committee stage on 24 April 2025.

The bill looks to bring around the following key measures;

• the removal of the mandatory pre-application consultation stage in development consent orders (DCOs), alleviating developers, in principle, from consulting prescribed bodies, local authorities, the local community and persons with an interest in the land is removed;
• allowing promoters to seek consent for alternative consent outside the Nationally Significant Infrastructure Projects (NSIP) regime;
• the removal of consultation with individuals or entities that could make a relevant claim due to the impact of a DCO ("category three persons");
• updates to the National Policy Statement (NPS) every five years, which ties in with consultations the government is undertaking around their content;
• fast-tracking legal challenges and creating more legal hurdles for their pursuit in meritless applications (for example, allowing applications to be decided at oral hearing); and
• the establishment of a Nature Restoration Fund managed by Natural England which will undertake large-scale conservation efforts, with developers making a financial contribution to the fund thereby discharging their environmental obligations.

New standards released by the UN for setting up a carbon market under the Paris Agreement

The Paris Agreement Crediting Mechanism (PACM) (also known as Article 6.4) is a carbon crediting mechanism established under the Paris Agreement which enables countries, companies and individuals to work together to reduce greenhouse gas emissions through the generation of carbon credits.

At the latest PACM supervisory body meeting, two new standards were proposed in draft form:

• A standard for estimating emission that would have occurred without a project under PACM (the "baseline"). This includes setting downward adjustments of the baseline to help avoid over-crediting.
• A standard for measuring any unintended increases in emissions that might have happened elsewhere as a result of a project ("leakage"). The aim is to develop methodologies that capture all potential sources of emissions related to a project.

Beyond these two standards, the PACM Supervisory Board proposed additional steps to ensure that carbon credits under PACM are "ambitious, real and verifiable." These steps include a process of consultation on how project benefits can be shared between countries as well as a renewed focus on capacity building to help countries participate in PACM.

The Supervisory Body is expected to approve the first PACM methodologies by the end of 2025.

Council of Europe new environmental strategy and protection of environment through criminal law

On 14 May 2025, the Council of Europe unveiled its new Strategy on the Environment for 2025 to 2030. This strategy aims to tackle the environmental crisis by integrating human rights into environmental policies, enhancing democratic governance, supporting environmental defenders, and prosecuting environmental crimes. It also prioritises the protection of wildlife, ecosystems and landscapes, and advocates for national recognition of the right to a clean, healthy and sustainable environment. A significant part of this strategy is the introduction of the new Convention on the Protection of the Environment through Criminal Law.

The convention's primary objective is to strengthen environmental protection by preventing and combating environmental crimes, fostering national and international cooperation, and establishing minimum legal standards for states' national legislation.

As an international legally-binding instrument, it provides a framework for states to address serious environmental crimes. The UK is among the 46 state parties to the Council of Europe.

Key features of the convention include:

• A comprehensive definition of the environment, encompassing air, soil, water, ecosystems and services, wild fauna and flora, and habitats.
• A broad range of environmental offences, allowing states to prosecute intentional acts leading to environmental disasters, including "particularly serious offences" akin to ecocide.
• Provisions addressing corporate liability, sanctions, jurisdiction, and organised crime.
• A monitoring mechanism to ensure effective implementation and accountability.