NOW Advisors Hub

NOW Advisors Hub Services

I

Access to Green Partners Academy FOC in year one.

II

  • Access to * Sustainability Specialists on project or retainer basis
  • ** Internal Audit & Baseline Review
  • Train Green Team or Coordinator
  • Prepare Audit Reports
  • Audit Preparation / Attendance
  • External Sustainability Officer
  • Hotel Group Certification (1 Corporate certification for all hotels)

* Credentials: Hotel experience. Trainer and Lead Auditor Certification from ISO14001 & ISO-EMS, EarthCheck Certified, EU Ecolabel. Auditor with Control Union.

** Internal Audit deliverables: Audit report on 20 topics - sustainability knowledge, practices, training, measurements, certification, audits, Environmental Management System and regulation compliance. Identification of cost-saving opportunities across energy, water, waste and compliance. Tailored Action Plan with quantified benefits. Advisory note on sustainability criteria or scheme certification. Outcome: Hotel gains a complete baseline, visibility of financial savings and can proceed to strategy and framework design.

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Sustainability Frameworks in Europe

Here’s the situation in Europe on regulations around sustainability which we update quarterly.

For Hotel Owners or CEOs or GMs, we included the laws from government websites and Insights from 3rd parties that you should be reading to simplify regulations.



Q1 2026 Update - EU Sustainability Framework & Insights +

The EU Sustainability Framework is a comprehensive set of regulations, directives, standards, and initiatives, anchored by the European Green Deal, aiming to shift the EU economy to a climate-neutral, sustainable model by 2050, primarily through mobilizing private investment in green activities, enhancing corporate transparency, and preventing greenwashing.

This interconnected system classifies sustainable activities, mandates disclosures for financial products and companies, and sets due diligence rules for responsible business, all while balancing environmental goals with economic competitiveness.

EU regulations are binding legal acts that apply directly and uniformly across all European Union member states, becoming law automatically without needing national legislation. They are comprehensive, binding in their entirety, and aim to ensure consistent application of EU law for citizens, businesses, and governments.

EU directives must be transposed into national law by Member States by the deadline date or they risk infringement procedures by the European Commission, potentially leading to European Court of Justice (ECJ) fines.

Communications, Reporting & Disclosure

EU Corporate Sustainability Reporting Directive (CSRD) +
Mandates extensive sustainability reporting for large companies, replacing the Non-Financial Reporting Directive (NFRD) and requiring adherence to the European Sustainability Reporting Standards (ESRS).

EU CORPORATE SUSTAINABILITY REPORTING DIRECTIVE (CSRD) Directive (EU) 2022/246

Adopted
Nov. 28, 2022
Published
Dec. 16, 2022
Enforced
Jan. 5, 2023
Transposed in EU Member States deadline
Jul. 6, 2024
Applied in Phases Report
FY2024 FY2025/2026 FY2027/2028
Omnibus/ Stop-the-Clock transposition delayed to
Dec. 31, 2025

The CSRD is European Union (EU) legislation that require companies above certain sizes and listed companies to publish regular reports on what they see as the risks and opportunities arising from social and environmental issues, and on the impact of their activities on people and the environment.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for non-compliance.

  • Heavy financial fines (eg. up to €10M or 5% of global turnover in Germany or France's up to €18,750)
  • Public disclosure ("naming and shaming")
  • Criminal sanctions for severe breaches ie. Up to 5 yrs imprisonment in France for failing assurance or obstructing audits (lack 3rd party audit from accredited Assessment Body)
  • Fines and exclusion from public contracts for general non-compliance
  • Significant reputational damage
The Omnibus Package

Omnibus Package was launched in 26 February 2025 to simplify and increase focus on EU competitiveness by reducing administrative burdens by 25% for all businesses and 35% for SMEs. Modifies CSRD.

  • Narrowed Scope: CSRD will primarily apply to large companies with over 1,000 employees, reducing the number of directly affected entities.
  • Delayed Reporting Timelines:
    • FY 2024 (due 2025): Large public-interest entities (500+ employees) already subject to previous NFRD.
    • FY 2025/2026 (Delayed): Other large companies and listed SMEs were originally set to report, but this is being postponed by the "Stop the Clock" Omnibus proposal, with many moving to FY 2027/2028 (due 2028/2029).
    • Non-EU Companies: Must start reporting in 2029 (for FY 2028).
  • Omnibus Package has a broad reach. Despite scope changes, the interconnectedness with EU partners means many non-EU companies (like Swiss firms) must still comply or adapt to meet supply chain requirements. While SMEs are not directly in scope, they will face significant indirect pressure from large partners to provide data and prove their credible sustainability credentials.


The ‘Stop-the-clock’ directive postpones by one year the application of certain due diligence requirements and transposition deadline; and by two years, the entry into application of the CSRD requirements for large companies that report from financial year 2025 and 2026 (so‑called “wave two” and “wave three” companies), as well as listed SMEs. A targeted “quick fix” amendment was also adopted to reduce burden for companies that had to start reporting for financial year 2024 (commonly referred to as “wave one”).

INSIGHTS

KPMG: Mar. 17, 2025 - Omnibus Simplification Package of the European Commission

PwC Switzerland: Mar. 3, 2025 - EU Commission publish Omnibus Proposal

Boston Consulting Group: Mar. 2025 - EU Omnibus Package - How Companies Should Adjust their Sustainability Reporting

Deloitte: Feb. 16, 2025 - European Sustainability Reporting - Omnibus

Stibbe: Jan. 7, 2022 - Omnibus I: clarity on the future of the CSRD and CSDDD

NOW Insight: Impacts to the Hospitality Industry

CSRD significantly impacts the hospitality industry by mandating detailed ESG (Environmental, Social, and Governance) Reporting, driving operational changes towards sustainability (environment, social and financial) and increasing transparency to all stakeholders.

This creates challenges (administrative burden, data collection) and opportunities (competitive advantage, resource efficiency) for hospitality companies, especially larger ones and those catering to business travel (MICE). For mandatory reporting and communication to stakeholders, companies must now rigorously track metrics like energy, water, waste, and carbon footprint to align with new European Sustainability Reporting Standards (ESRS), implement a sustainability criteria or standard which must be audited by an accredited Assessment Body to obtain certifications.

CSRD elevates sustainability from a voluntary marketing point to a mandatory, data-driven business imperative for the hospitality sector, especially for those serving the EU market.

EU Empowering Consumers for the Green Transition Directive (ECGTD) +
Sets rules for environmental / sustainability claims by companies to prevent greenwashing and give consumers better information about a product’s sustainability and encourage more sustainable purchases.

EU EMPOWERING CONSUMERS FOR THE GREEN TRANSITION DIRECTIVE (ECGTD) Directive (EU) 2024/825

Adopted
Feb. 28, 2024
Published
Feb. 28, 2024
Enforced
Mar. 27, 2026
Transpose in EU Member States
Mar. 27, 2026
Apply rules in EU Member States
Sept. 27, 2026

ECGTD is European Union (EU) legislation that aims to stop “greenwashing” by giving consumers better information about a product’s sustainability and encourage more sustainable purchases. It has a broad reach, affect all companies in the EU and abroad that target the EU consumer.

It amends and makes stricter two existing EU directives: Consumer Rights Directive: Officially Directive was updated to include product durability, repairability, and software updates for digital goods. Unfair Commercial Practices Directive was updated to ban misleading environmental claims and expand the list of misleading practices.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for non-compliance.

  • Substantial fines up to 4% of annual turnover or €2 million
  • Confiscation of illicit revenue
  • Public exposure
  • Bans from the market enforced by national bodies leveraging Unfair Commercial Practices Directive (UCPD) powers
  • Temporary exclusion from public tenders and access to public funds
INSIGHTS

PwC Switzerland: Jun. 5, 2025 - ECGT Directive: Prove Your Sustainability Claims Are True!

OECD: May 2025 - Protecting & Empowering Consumers in the Green Transition – Misleading Green Claims

Bird & Bird: Feb. 22, 2024 - Directive to Empower Consumers for the Green Transition has been published

Compliance & Risk: Mar. 11, 2024 - EU Adopts Stricter Rules on Greenwashing & Misleading Product Information

NOW Insight: Impacts to the Hospitality Industry

ECGTD will significantly impact the hospitality businesses in the EU and abroad if they are targeting the EU consumer.

Companies will have to prepare for scrutiny - what they communicate to all stakeholders, their sustainability criteria or certification scheme which should be audited and certified by an independent accredited Certification Body (Conformity Assessment Body), and the product lifespan and repairability for hotel items (linens, furniture, appliances, etc).

Companies reporting or communicating any sustainability related information should ensure all claims are backed by evidence and verifiable data and should be accessible to stakeholders in at least one official language of the country the communication is visible.

EU Taxonomy Regulation (EUTR) +
A classification system defining environmentally sustainable economic activities, guiding investments towards green goals like climate mitigation, circular economy, and pollution control.

EU TAXONOMY REGULATION (EUTR) Regulation (EU) 2020/852

Adopted
Jun. 2020
Published
Jun. 22, 2020
Enforced
Jul. 12, 2020
Applied in phases while EU Member States transposed related rules CSRD/CSDDD into national law. Started
Jan. 1, 2022

EUTR is a EU classification system that defines what counts as an environmentally sustainable economic activity.

It creates a common language to guide investments towards the European Green Deal goals, preventing greenwashing, and directing capital to green projects by setting clear criteria for six environmental objectives, including climate change mitigation, biodiversity, and circular economy. It requires large companies and financial market participants to report on the sustainability of their activities, aligning with the Sustainable Finance Disclosure Regulation (SFDR).

Penalties

The EU Taxonomy is a classification tool, but its disclosure requirements under related laws mean that failing to comply with taxonomy reporting effectively means failing to meet broader ESG obligations, leading to significant financial, legal, and market consequences.

Non-compliance leads to significant indirect penalties - fines, reputational damage, loss of investment, legal action, and market barriers - enforced by Member States under related ESG rules (like CSRD/SFDR) with potential jail time (up to 3 years) and massive corporate fines (e.g., 5% of turnover/2x benefit) for severe breaches, making robust, accurate reporting crucial.

INSIGHTS

KPMG: Get ready for the EU Taxonomy Regulation

Société Générale Securities Services: Everthing you need to know about the Taxonomy regulation

NOW Insight: Impacts to the Hospitality Industry

EUTR encourage hospitality companies to become demonstrably green by demanding stricter environmental standards, especially in building efficiency for construction/renovation, water-saving fixtures, energy, waste management and reporting, requiring significant investments in sustainable practices, renovations, and tech to meet criteria for "substantial contribution" to EU green goals, benefiting from potential financial incentives and meeting investor/consumer demand for sustainability.

Larger hospitality businesses must disclose their alignment with the Taxonomy, showing what percentage of their turnover, CapEx, and OpEx meets sustainable criteria. This requires detailed data collection and reporting under related rules like the Corporate Sustainability Reporting Directive (CSRD).

There are many opportunities for compliance. EUTR help channel finance towards sustainable hotels. Long-term efficiency gains from reduced water and energy use lower operating costs. Meeting the demand from eco-conscious travellers can potentially increase revenue. It future-proof businesses by aligning with evolving EU Green Deal objectives which will lead to stricter rules.

EU Sustainable Finance Disclosure Regulation (SFDR) +
Regulates sustainability-related disclosures for financial market participants, focusing on ESG factors in investments.

EU SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR) Regulation (EU) 2019/2088

Adopted
Nov. 27, 2019
Published
Dec. 9, 2019
Enforced
Dec. 29, 2019
Applied in phases. Level 1: Mar. 10, 2021
Level 2: Jan. 1, 2023
Taxonomy related amendments: Feb. 20, 2023
Revised simplification proposal delayed to 2027-2028

The Sustainable Finance Disclosure Regulation (SFDR) is a European Union rule requiring financial firms (asset managers, advisors, etc.) to be transparent about how they integrate sustainability risks and impacts (ESG factors) into their investment processes, telling investors how their products affect the environment/society and how sustainability risks affect returns. Its main goals are to combat greenwashing, help investors make informed choices, and channel finance toward sustainable goals by standardizing disclosures on websites, in prospectuses, and annual reports.

Penalties

SFDR doesn't have a single EU-wide penalty system, but firms must treat SFDR compliance seriously. Non-compliance leads to enforcement by national regulators (NCAs), resulting in varied penalties like significant fines, reputational damage, "greenwashing" accusations, and legal actions with tougher stances expected as regulators focus on misleading ESG claims and insufficient documentation.

INSIGHTS

KPMG: What is SFDR?

PwC Swirzerland: Aug. 27, 2020 - Sustainable Finance Disclosure Regulation (SFDR)

Société Générale Securities Services: Oct. 14, 2025 - Sustainable Finance Disclosure Regulation (SFDR)

NOW Insight: Impacts to the Hospitality Industry

SFDR impacts the hospitality industry by pushing investors and operators towards greater ESG (Environmental, Social, Governance) transparency. It drives demand for sustainable assets, influencing capital flows, and increasing pressure for verifiable green practices.

Ultimately, it affects property valuations and financing costs for hotels, restaurants, and travel platforms. It forces compliance with detailed disclosures, making it harder to "greenwash" and easier for investors to compare sustainability claims, shifting investment towards truly sustainable or decarbonizing properties.

EU Whistleblowers Directive +
Establishes minimum standards across the EU to protect individuals reporting breaches of EU law

EU WHISTLEBLOWING DIRECTIVE Directive (EU) 2019/1937

Adopted
Oct. 23, 2019
Published
Nov. 26, 2019
Enforced
Dec. 16, 2019
Transposed in EU Member States
Dec. 17, 2021
Applied in EU Member States
Jul. 2024

The EU Whistleblowing Directive is a European Union (EU) legislation aimed at providing high-level, consistent protection for whistleblowers, individuals who report information they acquired in a work-related context on breaches of EU law. It aims to encourage reporting of wrongdoing and safeguarding whistleblowers' freedom of expression.

Whistleblowing Platforms

The European Commission has established its own anonymous whistleblower tools for antitrust, the AI Act, the Digital Services Act (DSA), and the Digital Markets Act (DMA).

While the Directive mandates confidential reporting, several EU countries have gone further to explicitly permit or require that organizations and public authorities allow anonymous whistleblowing platforms.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for companies that hinder reporting or retaliate against whistleblowers.

  • Target failures to create reporting channels, obstructing reports, and retaliation against whistleblowers
  • Fines potentially reaching Euro tens of thousands for individuals and over €100,000 for companies,
  • Potential GDPR fines and civil/criminal liability for severe breaches.
  • Penalties can include imprisonment for knowingly false reports, while companies face financial sanctions, operational disruptions, and reputational damage.


NOTE: European Commission is actively monitoring compliance, with significant fines already being handed out to countries and organizations that fail to comply. Focus is shifting to how well these systems are implemented and whether they truly protect whistleblowers, not just that they exist. This aligns with broader efforts to protect whistleblowers from "Strategic Lawsuits Against Public Participation" (SLAPPs).

INSIGHTS

PwC Switzerland: EU Whistleblowing Directive

EU Whistleblower Center: EU Whistleblowing Directive

Bird & Bird: EU Whistleblowing Directive

NOW Insight - Impacts to the Hospitality Industry

Significantly impacts the hospitality industry, especially those with 50 or more employees. It requires them to create secure, confidential channels for staff to report EU law breaches of sustainability rules, fraud, health/safety violations, or unfair labour.

Companies should set up internal channels that meet Directive standards for confidentiality and accessibility, train staff on the process and their rights, ensure existing HR or compliance processes can handle whistleblowing reports effectively and make it safe for employees to speak up about any health, safety, financial and sustainability irregularity issues.

Supply Chain & Products

EU Corporate Sustainability Due Diligence Directive (CSDDD) +
Requires large companies to identify, prevent, and mitigate adverse human rights and environmental impacts in their operations and value chains.

EU CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE (CSDDD) Directive 2024/1760

Adopted
May 24, 2024
Published
Dec. 16, 2022
Enforced
Jul. 25, 2024
Transpose in EU Member States Deadline
Jul. 26, 2026 Delayed to
Jul. 26, 2027
Applied in EU Member States:
2027, 2028, 2029

The CSDD is European Union (EU) legislation and apply to large EU companies and large non-EU companies selling in the EU, typically those with over 1,000 employees and significant turnover. Require companies to integrate due diligence into their management systems, identify adverse human rights and environmental impacts in their operations, subsidiaries and global supply chain to prevent or mitigate them, assess effectiveness, communicate findings, and provide remediation. It covers the entire value chain, from raw material extraction and manufacturing to transportation and distribution.

Fines and Penalties

Strict penalties for non-compliance that vary by EU Member State and designed to be effective, proportionate, and dissuasive.

  • Fines up to 5% of a company's net worldwide turnover
  • Public disclosure ("naming and shaming")
  • Civil liability for damages to victims (with potential for collective redress)
  • Large fines and criminal sanctions for severe breaches ie. Up to 5 yrs imprisonment in France for directors failing assurance or audit obstructing (lacking 3rd party audit by an accredited Assessment Body)
  • Exclusion from public contracts
INSIGHTS

PwC SWITZERLAND: Feb. 24, 2025 - CSDDD: A game changer for your supply chain

CDP INSIGHT GROUP: CSDD: Corporate Sustainability Due Diligence Directive

DELOITTE: CSDDD: Corporate Sustainability Due Diligence Directive

Omnibus I: Clarity on the future of the CSRD and CSDDD

NOW Insight: Impacts to the Hospitality Industry

CSDDD significantly impacts the hospitality industry. Companies must prepare for a significant increase in due diligence obligations focused on human rights and environmental impacts throughout their value chain.

This will require data transparency, and potentially influencing smaller hotel operators to comply with demands from major clients, impacting everything from energy use to fair labour practices.

EU Ecodesign for Sustainable Products Regulation (ESPR) +
Aims to make products more sustainable, durable, and repairable, replacing the older Ecodesign Directive

EU ECODESIGN FOR SUSTAINABLE PRODUCTS REGULATION (ESPR) Regulation (EU) 2024/1781

Adopted
Jun. 2024
Published
Jun. 28, 2024
Enforced & Applied in EU Member States
Jul. 18, 2024

The ESPR is European Union (EU) legislation that established a framework for sustainability product rules, enhancing the existing Ecodesign Directive (2009/125/EC) to cover more products, introduce digital passports, and align with circular economy goals, while also linking to consumer protection via the Representative Actions Directive.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

  • Heavy fines that consider the nature, gravity, and duration of the infringement, the economic benefits derived, and the environmental damage.
  • Non-compliant products can be banned or removed access to EU market.
  • Temporary exclusion from public procurement procedures is a mandated penalty.
  • Consumers can seek compensation for damages caused by non-compliant products, enabling private enforcement and collective/representative actions against manufacturers and importers.
  • National authorities may seize or destroy non-compliant products.
INSIGHTS

SGS: Jul. 3, 2025 - How will the EU ESPR & DPP impact consumer product markets

Greenly: Sept. 3, 2025 - What is the Ecodesign for Sustainable Products Regulation (ESPR)?

ECOS: Jan. 15, 2025 - Ecodesign: The EU’s journey to sustainable products begins now

NOW Insight - Impacts to the Hospitality Industry

ESPR indirectly impacts the hospitality businesses as large buyers and users of these goods.

Companies should audit their supply chain to understand where current products fall under ESPR rules, prioritize suppliers offering products meeting verifiable durability, repair, and circularity standards. Hotels should align with ESPR goals and focus on reducing waste, water and energy use, and plan to use and provide information from Digital Product Passports.

EU Deforestation Regulation (EUDR) +
Bans the EU market for products linked to deforestation (e.g., coffee, cocoa, palm oil, soy) and mandates strict supply chain due diligence.

EU DEFORESTATION REGULATION (EUDR) Regulation (EU) 2023/1115

Adopted
May 2023
Postponed & Simplified
Dec. 17, 2025
Published
Dec. 23, 2025
Enforced & Applied
Dec. 30, 2026 (L&M Operator)
Jun. 30, 2027 (S&Micro Operator)

The EUDR is European Union (EU) legislation aims to ensure that products sold in the EU are not sourced from deforested land with the goal to reduce the EU's contribution to global deforestation and forest degradation, cutting emissions and preserving biodiversity.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

  • Fines up to 4% of a company's total EU turnover
  • Confiscation of non-compliant products or related revenues
  • Temporary bans from the EU market
  • Exclusion from public procurement/funding
  • Public disclosure of infringements for severe cases
  • Potential personal liability for directors under national laws
INSIGHTS

KPMG: EUDR and deforestation: How Swiss businesses can prepare for EUDR compliance

PwC Switzerland: Mar. 3, 2025 – EUDR Regulation on Deforestation-free Products

Deloitte: The European Union Deforestation Regulation (EUDR)

NOW Insight - Impacts to the Hospitality Industry

EUDR significantly impacts the hospitality industry. The supply chain is scrutinised, requiring due diligence & traceability, including precise geolocation of production plots to prove no deforestation occurred after 2020.

Companies are required to prove that products used in their operations are deforestation-free and sourced legally from their country of origin, focusing on geolocation data to trace the origin of key commodities (cattle, soy, cocoa, coffee, palm oil, rubber, wood) and their derivatives, including items like wooden furniture, coffee, and meat.

This affects procurement, requiring new processes for vetting suppliers. Companies will need to select compliant suppliers who can provide concrete evidence, shifting responsibility to those placing products on the EU market.

Climate & Environment

European Climate Law +
Makes the EU's climate neutrality by 2050 goal legally binding and sets a target reduction for 2030 & 2040

EUROPEAN CLIMATE LAW Regulations (EU) 2021/1999

Adopted
Jun. 30, 2021
Published
Jul. 9, 2021
Enforced
Jul. 29, 2021
Applied in EU Member States
Jul. 29, 2021

European Climate Law legislates the goal of the European Green Deal for Europe’s economy and society to become climate-neutral by 2050, which means achieving Net Zero GHG emissions for EU Member States.

The law compels businesses to integrate sustainability into their core operations and sets the intermediate target of reducing net greenhouse gas (GHG) emissions by 55% reduction by 2030, 90% reduction by 2040, negative emissions by 2050. In June 2025, a new proposal to amend the European Climate Law encourage reliance on carbon removal technologies (such as BECCS and DACCS) and permit carbon offsetting to reach the EU greenhouse gas emission reduction targets.

Penalties

Significant penalties to be imposed on individuals and companies to create stronger deterrents across the EU for environmental and sustainability violations.

  • Major fines (3-5% of global turnover or €24-€40 million for companies) plus environmental restoration
  • Exclusion from public funding
  • Permit withdrawal
  • Prison sentences (up to 10 years for severe offenses)
INSIGHTS

MORGAN LEWIS: Jan. 7, 2026 - 2040 EU Climate Target and Related EU Climate Policy Developments

CARBON GAP: Oct. 26, 2025 - EU Climate Law (ECL)

STIBBE: Mar. 2025 - The European Climate Law Explained

NOW Insight: Impacts to Hosptiality Industry

Significantly impacts the hospitality industry requiring

  • Green claims & marketing to be accountable, transparent and verifiable with credible certification
  • Energy efficiency & investment requiring energy efficient upgrades and renewables
  • Decarbonization / Net Zero Plans with monitored roadmap to achieve reduction targets


Hotels should audit operations and review baselines, invest in green tech, and seek audits and certifications by an independent, accredited assessment bodies.

EU Carbon Border Adjustment Mechanism (CBAM) +
Puts a carbon price on imports of certain goods, encouraging cleaner production globally.

EU CARBON BORDER ADJUSTMENT MECHANISM (CBAM) Regulation (EU) 2023/956

Adopted
Apr. 18, 2023
Published
Oct. 8, 2025
Transition Phase Began
Oct. 2023
Definitive Implementation Phase
Jan. 1, 2026

The Carbon Border Adjustment Mechanism (CBAM) is a climate policy that places a carbon tariff on the carbon emitted during the production of carbon-intensive products (such as iron and steel, cement, fertilizers, aluminium, electricity and hydrogen ) imported to the European Union, and encourage cleaner industrial production in non-EU countries. It also prevents "carbon leakage" where companies move production to countries with weaker climate rules.

CBAM ‘s transitional phase of 2023 to 2025 is aligned with the phase-out of free allowances under the EU Emissions Trading System (ETS) to support the decarbonisation of EU industry. The EU ETS is the world’s first and largest "cap-and-trade" carbon market, launched in 2005 to reduce greenhouse gas emissions. It sets a legal limit on emissions for power, industry, and aviation sectors, requiring companies to buy allowances for each tonne of CO2 emitted, covering ~40% of the EU's total emissions.

Penalties

Penalties are designed to ensure compliance with the CBAM regulations and to prevent carbon emissions being shifted to low-regulation markets.

  • Penalty for unreported emissions during Transitional Phase (ending 2025): Between €10 and €50 per tonne of emissions that are not reported accurately.
  • Penalty for unreported emissions during Definitive Implementation Phase (starting Jan. 1, 2026): Significant fines linked to the EU ETS price (€100+/tonne) for failing to surrender certificates, with potential for persistent non-compliers to be barred from the EU market, alongside domestic penalties set by member states.
  • Penalty for missing, incorrect, or incomplete CBAM reports: The National Competent Authority (NCA) may initiate a correction procedure, which allows reporting declarants to rectify potential errors.
  • Penalty for failing to surrender sufficient CBAM certificates: Declarants will be liable to pay a penalty identical to the penalty under the EU ETS applicable in the year of importation of the goods.
INSIGHTS

PwC SWITZERLAND: The Carbon Border Adjustment Mechanism

KPMG: Navigating the EU Carbon Border Adjustment Mechanism (CBAM)

WORLD ECONOMIC FORUM: Dec 15, 2025 - How the EU's CBAM will impact the business and carbon pricing

INTL MONETARY FUND (eLibrary): Nov 5, 2025 - Implications for Member States and Trading Partners

EU Industrial Emissions Directive (IED) +
Focuses on preventing and controlling pollution from industrial activities.

EU INDUSTRIAL EMISSIONS DIRECTIVE (IED) Directive (EU) 2010/75

Adopted
Apr. 12, 2024
Published
Jul. 15, 2024
Enforced
Aug. 4, 2024
Transpose in EU Member States Deadline:
Jul. 1, 2026
Apply in EU Member States:
2030 - 2032

IED is the main EU instrument designed to prevent and control pollution from large industrial installations and intensive livestock farming. It aims to reduce harmful emissions to air, water, and soil to achieve a zero-pollution, climate-neutral economy by 2050. Focuses on preventing and controlling pollution from industrial activities.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

  • Maximum fines of at least 3% of the operator's annual EU turnover plus Member States are required to establish a system of penalties to include further administrative fines.
  • Individuals to seek compensation for damages to their health caused by violations of national rules implementing the IED.
  • Suspension of operations.
INSIGHTS

KPMG: Jan. 13, 2025 - IED: First legislative package to implement the EU directive is available

European Environmental Bureau: Aug. 4, 2024 - Revised Industrial Emissions Directive and Regulation

Nater & Partners: Apr. 29, 2024 - European Union Industrial Emissions Directive

NOW Insight: Impacts to Hospitality Industry

IED indirectly impacts the hospitality industry by raising overall environmental standards, pushing for energy/resource efficiency (water, chemicals), and mandating 'transformation plans' for sustainability.

This means that hospitality companies must innovate and invest in better tech (like EMAS systems) to reduce emissions, use less water/energy, manage waste better, and comply with stricter permitting, or risk higher fines and operational suspension, driving a shift towards greener, circular practices.

EU Batteries Regulation +
Establishes rules for sustainable batteries, covering their lifecycle and environmental impact.

EU BATTERIES REGULATION Regulation (EU) 2023/1542

The Batteries Regulation is an EU legislation that establishes rules for sustainable batteries, covering their lifecycle and environmental impact. It is designed to promote a circular economy and enhance environmental safety, including strict rules on recycling, material recovery, and carbon footprint.

Adopted
Jun. 14, 2023
Published
Jun. 28, 2023
Enforced
Aug 17, 2023
Applied in EU Member States:
General rules – Feb. 18, 2024
Waste Management – Aug. 2025
Digital Battery Passports – Feb. 2027
Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

  • Significant fines, potentially up to €100,000 per breach or even a percentage of annual revenue
  • Marketing and sales bans for products failing to meet requirements, such as lacking valid registration or compliance documentation
INSIGHTS

Brown & Jacobson: Jul. 22, 2025 - Compliance obligations under the EU Batteries Regulation

Bird & Bird: Sept. 24, 2024 - Due Diligence Policy Obligations under the new EU Batteries Regulation

NOW Insight: Impacts for Hospitality Industry

Significantly impacts the hospitality industry by increasing demands for sustainable, traceable, and recyclable batteries in devices (laptops, phones, e-bikes, etc.). This will make it easier for companies to make sustainable choices and access digital information.

Stricter rules mean companies will need efficient systems for collecting and returning used batteries (portable, LMT, industrial) for recycling, possibly through manufacturer take-back schemes. Companies will also have to update purchasing policies to favor compliant, sustainable batteries and devices even if it cost higher initially.

EU Waste Framework Directive (WFD) +
Set a hierarchy (prevent, reuse, recycle, recover, dispose) and establish binding recycling targets for municipal, packaging, and specific waste streams.

EU WASTE FRAMEWORK DIRECTIVE (WFD) Directive (EU) 2008/98/EC

Adopted
Sept. 9, 2025
Published
Sept 26, 2025
Enforced
Oct .16, 2025
Transposed in EU Member States
Jun. 17, 2027
Applied in EU Member States
Apr .2028

WFD is the EU's foundational law for waste management, promoting the waste hierarchy (prevention, reuse, recycle, recovery, disposal) and principles like the ."polluter pays" and Extended Producer Responsibility (EPR).

A major revision was enforced in October 2025, introducing binding food waste reduction targets (10% in manufacturing, 30% per capita) and new EPR schemes for textiles and footwear, aiming for greater circularity in the EU.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

  • Penalties are high for improper waste separation, hazardous waste mismanagement and EPR non-compliance for when producers fail to register or pay fees for waste management.
  • Fines can be severe, such as in the Czech Republic, where failure to comply with food donation obligations can result in fines up to €400,000 (10 million CZK).
  • Legal action & criminal charges are severe for repeated, or negligent breaches, particularly concerning illegal dumping of hazardous waste which can lead to criminal prosecution.
INSIGHTS

Stibbe: Oct. 23, 2025 - Amendment to the Waste Framework Directive

European Food Banks Federation: Mar. 10, 2025 - Revised Waste Framework Directive: A Milestone for Food Waste Reduction and Food Donation in Europe

NOW Insight: Impacts to Hospitality Industry

WFD impacts the hospitality industry by imposing binding food waste reduction targets (30% per capita by 2030 for restaurants/hotels/food services), mandating measurement & reporting, promoting food donation, and encouraging technological innovation. It requires substantial operational changes for kitchens and a shift from guesswork to data-driven waste management, affecting everything from procurement to guest engagement to meet stricter sustainability goals.

This directive reinforces other EU rules, like those on greenwashing (UCPD/CRD) and corporate reporting (CSRD), pushing the sector towards greater transparency and sustainability.

Reduced waste directly lowers food costs, benefiting the bottom line, especially for SME. It minimizes resource depletion associated with food production and disposal. And it demonstrates commitment to sustainability, appealing to environmentally conscious consumers.

Q1 2026 Update - Swiss Sustainability Framework & Insights +

Available soon.

Q1 2026 Update - UK Sustainability Framework & Insights +

Available soon.

WHAT HOTELS SHOULD DO NOW?

Be informed and do what you do best ... continue to operate a successful hotel.

Retain a qualified Sustainability Specialist to gear up for A.C.T.I.0.N.

Empowering Consumers for the Green Transition Directive (ECGTD)

On March 27th of 2026, the ECGTD will be enforced, and all EU Member States have 6 months to transpose it into national law. The deadline is September 26, 2026.

DO NOT WAIT until deadline date. Some EU countries have their draft national law ready now for early enforcement. ECGTD will affect all businesses in the EU and abroad that targets the EU consumer. There are serious penalties and fines

You have a choice! Talk about verified sustainability … or HUSH and do not talk about sustainability (this is anything good you are doing for communities and the environment) in your website, in social media, in PR activities and in print materials.

NOW can help.

KNOWLEDGE

You need training to build capacity & achieve your goals

We will give access to a knowledge platform starting with top management followed by employees

GREENWASHING

Tell us what you do & claim about sustainability

We will advise whether you are Greenwashing or not

REAL GREEN CLAIMS

Tell us what you claim about sustainability

We will train you on transparent greenwash-proof reporting (Sustainability, ESG & CSR) to be compliant with Green Claims Directive

ADVICE

Tell us your problem

We will advise on certification schemes, implementation & audit preparation to be compliant, & greenwash-proof reporting & communications to engage stakeholders

“WE CAN HELP YOU”

SCALABLE SOLUTIONS

CONSULTANCY

Tell us what challenges you

Specialists & Coaches in sustainability, decarbonization, sustainable design & MarComm will help you understand regulations that affect your business & propose strategies & scalable solutions.

INTERNAL AUDIT

You don’t know where to start & don’t know exactly what is wrong

We will assess sustainability efforts & staff knowledge in relation to regulations, to identify where to save money with little or no investment. Prepare pre-audit reports & rehearse the audit day activity

SUPPLIERS AUDIT

You have doubts about what your supplier claims about sustainability

We will audit your supplier & determine whether they are greenwashing or not

MONITORING

You have achieved your goals & want to improve them even more

We will monitor your achievements & define the process of continuous improvement including pre-audit preparation to obtain certification

Certifications

NOW recommends globally recognised standards – EarthCheck, EU Ecolabel and ISO - that are fully aligned with current European regulations and leads in environmental responsibility.

Achieving an accredited sustainability certification is about actioning a rigorous validation process. Certification standards provide a framework that the hotel business must align with fully. The certification will only be awarded when the operations meet these standards.

  • EarthCheck +

  • EU Ecolabel +

  • ISO 14001 / ISO 9001 / ISO 50001 / ISO 26000 +

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