Crackdowns on deforestation, consistent oversight on pollution, and increased scrutiny on green claims: Lexology PRO analyses environment enforcement trends and what they mean for businesses.
The data in this article is based on Lexology PRO’s Scanner, our automated regulatory monitoring tool covering 18 regulatory areas and tracking over 1500 regulatory sources. Full details on Scanner’s regulatory coverage can be found here.
Enforcement in this series includes any action regulators have taken as part of their enforcement powers, including active investigations, audits, decisions, fines, penalties, settlements, and/or orders. This report covers data – primarily agency announcements – released between 1 November 2024 and 1 November 2025.
Overall regulatory activity
Environmental compliance remains central to corporate resilience, despite ongoing changes in global ESG regulation. Businesses face a dual challenge: meeting disclosure obligations while mitigating environmental risks.
This analysis covers regulatory and enforcement trends across major G20 nations, to illustrate how these pressures play out in practice.
While enforcement data from Scanner shows strong activity in certain jurisdictions, disclosure practices vary widely. For example, Brazilian environmental regulators publish granular updates on operational actions, whereas the European Commission tends to focus on major policy-driven interventions, leaving routine enforcement to state regulators.
Across the most active jurisdictions, enforcement concentrated on environmental protection, waste management and pollution control. In parallel, some nations introduced major policy changes, including chemical restrictions, renewable energy permitting, and climate initiatives.
Enforcement strategies and key examples
The enforcement trends suggest that regulators are increasingly linking environmental compliance to broader ESG objectives, underscoring the importance of integrating sustainability compliance into corporate risk management strategies.
For example, the Brazilian Institute for the Environment and Renewable Natural Resources (IBAMA) launched Operation Metaverso II to combat fraudulent forest credits and timber laundering, seizing 1,500 hectares of forest and imposing fines totalling 107.5 million Brazilian real (US$20.2 million).
In Europe, the European Commission (EC) fined 15 car manufacturers and an industry association €458 million (US$528 million) for participating in a cartel that restricted the recycling of end-of-life vehicles.
These cases illustrate that environmental enforcement is evolving beyond traditional compliance to tackle ESG-related issues, such as transparency, ethical sourcing, and circular economy practices.
Environmental protection enforcement on the rise
Enforcement aimed at safeguarding ecosystems has intensified globally, particularly in regions rich in biodiversity. Brazil stands out with large-scale operations against illegal logging and mining. IBAMA (the Environment Ministry’s enforcement division) seized nearly 7,000m³ of illegal timber in Pará through Operation Maravalha , while Operation Xapiri-Sararé dismantled illegal gold mining camps in Mato Grosso.
Notably, Lexology PRO’s analysis shows IBAMA’s enforcement activity tripled year-on-year ahead of COP30, while nature and environmental protection cases dominated the Federal Public Prosecutor’s Office caseload.
Elsewhere, the Netherlands cracked down on illegal timber imports under the Timber Regulation 2010, imposing fines of €100,000 (US$115,406) each to 19 companies and mandating stricter documentation.
Wildlife protection enforcement also gained traction across several nations. In the Asia-Pacific (APAC) region, Chinese authorities focused on ecological protection and illegal wildlife trade. In September 2025, Hong Kong Customs intercepted 324 live turtles valued at HK$3.2 million (US$411,159) in a cross-border smuggling case.
Find out how Brazil cracked down on environmental crime in the buildup to COP30
Regulatory data reveals how deforestation, mining and indigenous rights came to dominate enforcement against companies in 2025 as Brazil prepared to host the global climate summit. Click here to access.
Waste, water, and air pollution remained consistent
Enforcement against pollution remained a key focus across industrialised jurisdictions, with regulators focusing on hazardous waste, water contamination, and gas emissions.
In the US, the Environmental Protection Agency (EPA) issued orders under the Clean Water Act 1977 to prevent spills into sensitive ecosystems, such as Apra Harbour in Guam. The EPA also pursued settlements for hazardous air emission violations under the Resource Conservation and Recovery Act 1976.
The UK Environment Agency adopted a similar approach, tackling pollution breaches via targeted prosecutions. A notable case involved East Midlands Airport, which was fined £892,500 (US$1.17 million) in July 2025, after pleading guilty to discharging drainage water containing aircraft and runway de-icing fluids above permitted levels.
South Korea followed suit with even tougher measures. The Ministry of Environment fined HD Hyundai Oilbank 176.1 billion won (US$119.37 million) for discharging phenol-laden wastewater, violating the Control and Aggravated Punishment of Environmental Offences Act 2017.
Enforcement linked to decarbonisation and energy transition
Companies are facing increasing enforcement scrutiny related to climate neutrality and energy transition goals. In Europe, the EC referred Sweden to the European Court of Justice for failing to transpose renewable energy permitting rules and Poland for not submitting its long-term climate strategy.
In the US, the EPA stepped up oversight on carbon capture and storage projects with an order on Archer Daniels Midland in August 2025 to ensure compliance at its Illinois carbon sequestration well after detecting fluid migration.
However, policy-adjacent litigation is emerging as a key risk in the US. Disputes over federal programme rollbacks in the US, such as the termination of Solar for All funding and offshore wind project timelines, highlight the growing intersection of climate policy with administrative law. Plaintiffs have filed lawsuits arguing that such rollbacks exceed statutory authority and breach procedural rules, creating regulatory uncertainty for businesses.
Regulators intensify efforts on misleading green claims
Beyond traditional environmental enforcement, regulators are tightening oversight of sustainability claims and product standards. France’s consumer protection agency issued corrective actions and fines against home equipment products that failed to meet energy labelling and reparability index requirements.
In Hungary, the consumer protection authority launched a nationwide audit of both traditional and online commerce, examining whether their sustainability claims and eco-labels are truthful and substantiated.
Meanwhile, Australia prioritised enforcement on ESG integrity and greenwashing, overseen by the Australian Securities and Investments Commission (ASIC) and the Australian Competition and Consumer Commission (ACCC). In a landmark case, the ACCC secured an A$8.25 million (US$5.32 million) penalty against Clorox Australia for misleading “ocean plastic” claims on certain products.
What should businesses expect from environmental enforcement in 2026 and beyond?
Enforcement risk persists despite regulatory divergence
ESG regulatory frameworks are under pressure. The EU has paused key sustainability reporting and due diligence laws, while the Trump administration has rolled back ESG policies. These shifts may lead to reduced environment-related enforcement activity, but businesses should remain vigilant and continue to monitor developments.
Lexology PRO analysis shows that US EPA enforcement decreased 64% between March and August 2025 compared to the same period in 2024. Yet, the share of cases with financial penalties rose from 40% to 65%, signalling a sharper focus on punitive measures.
Find out how EPA enforcement slashed by 64% under Trump administration
Regulatory data reveals how President Trump’s staffing cuts and strategy changes led to far fewer companies facing enforcement action in 2025 compared to the previous year. Click here to access.
Operational integration as a compliance response
Elsewhere, jurisdictions are moving from voluntary ESG frameworks to mandatory climate disclosure regimes. APAC countries, such as Australia, Hong Kong, and Singapore, require climate reporting. Some African nations, like Kenya and Nigeria, have adopted international standards.
This shift is driving a deeper transformation inside companies. Ernst Müller, director at Herbert Smith Freehills Kramer (HSFK) South Africa, notes a shift away from businesses making public commitments, such as climate decarbonisation targets, to integrating sustainability with legal, finance, or operations over the past year. He told Lexology PRO:
“This shows a move away from what some call ‘sustainability theatrics’ towards full-on financial integration of the sustainability function across business’ operating models."
Enforcement expands on greenwashing crackdowns
ESG transparency and anti-greenwashing will continue to be enforcement priorities. Authorities such as Canada’s Competition Bureau has pledged to continue crack down on misleading sustainability claims, while US state regulators have probed renewable energy claims by companies ranging from Big Tech to investments to meatpacking.
These actions go beyond administrative penalties. Julius Redd, Washington-based principal at Beveridge & Diamond, says they can:
“lead to enforcement cases and can spawn civil litigation targeting companies’ environmental marketing claims, so-called greenwashing litigation.”
Nadia Odendaal, trainee at HSFK South Africa, echoes:
"A consistent trend is the wide range of parties who can bring greenwashing claims. It’s not just class actions or strategic litigation brought by environmental activists, the cases businesses may anticipate, but also challenges from competitors and consumers."
Climate litigation as an emerging risk
As the regulatory environment develops, climate litigation is emerging as a parallel risk. Alongside the International Court of Justice’s advisory opinion on climate change, new cases are testing boundaries, such as Climate Action Professionals Zambia’s petition on whether individuals can sue the state for failing to implement climate measures. Müller adds:
“These are the types of questions we are used to seeing in the EU but will increasingly see across emerging markets and developing economies.”