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An oil major (“the Company”) filed suit in federal court on October 24, 2025, challenging California’s Climate Laws — the Climate Corporate Data Accountability Act (“SB 253”) and the Climate-Related Financial Risk Act (“SB 261”) — on the basis that the laws violate the Company’s First Amendment rights.

In a potential watershed moment that could reverberate across companies that have set climate goals or made claims regarding climate ambitions (e.g., “net zero” or carbon neutrality), on October 23, 2025, a European oil major (the “Company”) was handed a potentially significant greenwashing ruling by the Paris Judicial Court (the “Court”), which found the Company’s claims about its role in the energy transition and its net zero ambitions were likely to mislead consumers.

In the latest round of developments regarding California’s Climate Laws—SB 253 and SB 261—the California Air Resources Board (“CARB”) posted a Notice to its website on October 14, 2025, deferring its initial rulemaking on the laws until the first quarter of 2026 in response to the large volume of public comments it has received.

On July 3, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”), the U.S. Army Corps of Engineers (“Army Corps”), and the Departments of Energy (“DOE”), Interior (“DOI”), Transportation (“DOT”), Agriculture (“USDA”), and Defense (“DOD”) released sweeping updates to their regulations and procedures implementing the National Environmental Policy Act (“NEPA”).

On June 17, 2025 the U.S. Environmental Protection Agency (“EPA”) published a proposed rule to repeal the amendments to the Mercury and Air Toxics Standards (“MATS”) adopted by the Biden administration in 2024.

In the first major National Environmental Policy Act (“NEPA”) case to reach the Supreme Court in almost two decades, the U.S. Supreme Court issued its decision on May 29, 2025, in Seven County Infrastructure Coalition v. Eagle County, Colorado.

On May 1, 2025, the federal government brought separate suits against both New York and Vermont alleging that these state’s “climate Superfund” statutes are unconstitutional on multiple grounds.

On December 26, 2024, New York Governor Kathy Hochul signed the Climate Change Superfund Act (“CCSA” or the “Act”) into law.

On February 19, 2025, the Council on Environmental Quality (“CEQ”) released a pre-publication version of an interim final rule (the “Interim Rule”) to rescind all of CEQ’s previous and current regulations implementing the National Environmental Policy Act (“NEPA”) alongside a memorandum (the “Memo”) to federal agencies providing guidance on how agencies should revise their individual NEPA regulations and how they should manage NEPA reviews in the meantime.

In his first two days in office, newly inaugurated President Donald J. Trump signed a flurry of Executive Orders, including several aimed at supporting the traditional energy industry.

In early March 2024, the U.S. Securities and Exchange Commission (“SEC”) finalized its climate-related disclosures rule (The Enhancement and Standardization of Climate-Related Disclosures for Investors) (the “Final Rule”).