In this month's ESG alert, we highlight the adoption of two new Norwegian acts on food loss and marine protection, a landmark advisory opinion from the EFTA Court on the interpretation of the EIA Directive, adoption of a country risk classification under the EU Deforestation Regulation, and the proposed Omnibus IV package.

In this month's ESG alert, we highlight the EU 'Stop the Clock' Directive which entered into force on 17 April 2025, and the recent judgement from the Supreme Court of Norway on the interpretation of the rules on interim measures under the Norwegian Dispute Act.

In this month's ESG alert, we highlight the EU Commission's Omnibus package, which proposes significant simplifications to EU legislation on sustainability and human rights. We also describe the overturn of the first infringement penalty issued under the Transparency Act, and the proposed implementation of the EU Regulation on Waste Shipments into Norwegian law.

In this month's ESG alert, we highlight the entry into force of the reporting requirements of the EU Corporate Sustainability Reporting Directive in Norway, and look into the Omnibus Simplification Package and the postponement of the Deforestation Regulation from the EU, as well as a recently published report evaluating the Norwegian Transparency Act.

On 14 November 2024, the EU Parliament formally approved the European Commission's proposal to postpone the application of the Deforestation Regulation (Regulation (EU) 2023/1115) until 30 December 2025. With the aim of reducing deforestation, forest degradation, greenhouse gas emissions and global biodiversity loss, the Deforestation Regulation imposes documentation and due diligence requirements on in-scope entities to ensure that relevant commodities and products are deforestation-free and lawfully produced. Companies falling within the scope of the Regulation, should start preparations to ensure that they are prepared to comply once the obligations enter into force.

In this month's ESG alert, we highlight the first infringement penalty imposed under the Transparency Act, the implementation of the EU CSRD into Norwegian law, the Norwegian government's decision to implement CBAM into Norwegian law, EU restrictions on a sub-group of PFAS chemicals, and the latest decision from the Borgarting Court of Appeal regarding an injunction appeal from two environmental organisations.

The Norwegian Consumer Authority has on 25 September 2024 issued what appears to be the first infringement penalty for a failure to comply with the Norwegian Transparency Act. For not responding to two information requests on time, the Authority has imposed a penalty on a retail company of 450,000 NOK.

ESG, compliance and risk management

Sanctions and Export Controls

Responsible business and human rights

Corporate Criminal Liability

Anti-Money Laundering

Investigation and Crisis Management

Senior Associate

Mads works broadly with ESG, compliance and risk management. He has particular experience within human rights and responsible business conduct, and has co-authored the book "Åpenhetsloven i praksis", a legal commentary about the EU Corporate Sustainability Reporting Directive (CSRD) and an article in "Lov og Rett" about the Norwegian Transparency Act. Mads also works with other compliance areas, including anti-corruption, anti-money laundering, sanctions and export controls and sustainability.

Mads has previously worked in CMS Kluge, and has been a trainee at the Norwegian National Human Rights Institution and at various law firms. He has also worked as a teaching assistant at the Faculty of Law at the University of Bergen.

Mads holds a Master of Laws (LLM) degree from King's College London, as well as a master's degree in law from the University of Bergen. He has previously completed university courses in French, Spanish, history of ideas and history of art.

Oslo

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Mads works broadly within ESG, compliance and risk management. He has particular experience with human rights and responsible business conduct, and also provides advice within anti-corruption, anti-money laundering, sanctions and sustainability.