Commercially Connected Shorts - 4 March 2026

This week we look at:

• GB machinery safety regime to be aligned with new EU regime
• UK consultation on protecting children online
• ESG: final UK Sustainability Reporting Standards published
• How statutory warranty laws differ across jurisdictions

GB machinery safety regime to be aligned with new EU regime

On 26 February 2026 the Office for Product Safety & Standards (OPSS) published the outcome of its summer 2025 call for evidence on UK machinery safety regulation.

The OPSS is reviewing the Supply of Machinery (Safety) Regulations 2008, which implemented the EU Machinery Directive 2006 in the UK. These Regulations cover issues such as conformity assessments and they set out the legal basis for permitting CE marked machinery products to be placed onto the GB market.

From January 2027, in the EU, the EU Machinery Directive 2006 will be superseded by the Machinery Regulation 2023. Part of the OPSS call for evidence centred on the extent to which the UK’s machinery safety regime should be aligned with the new EU regime. 

The OPSS has confirmed that respondents to the call for evidence generally supported continued recognition of CE marking and alignment with the EU approach. There was also support for digitalisation – such as digital product passports and QR codes – to streamline compliance. Views on compulsory conformity assessments by third parties were more mixed, whilst mutual recognition of conformity assessment bodies was generally regarded as helpful.

The OPSS has confirmed that the Government now intends to legislate for continued CE recognition for machinery products in GB and to align the GB regime with the new EU regime insofar as possible. No timeline is given.

This approach will minimise trade friction between GB and the EU. It will also mean that the rules for putting an in-scope product on the GB market are aligned with the rules for the Northern Ireland market, as Northern Ireland has to follow certain EU product rules under the terms of the Windsor Framework. 

UK consultation on protecting children online

On 2 March 2026 the Department for Science, Innovation and Technology launched a consultation on potential measures to protect children online. This is framed as the next stage of online regulation following the Online Safety Act 2023, moving beyond regulation of illegal and harmful content to look at the impact of tech on children’s lives and wellbeing.

The consultation asks for views on matters including:

• how children use tech, and the associated benefits, harms and risks
• potential interventions to keep children safer online, with possibilities including a legal requirement for social media services to have a minimum user age (the “social media ban” that has been widely reported on in the media); raising the age of “digital consent” (i.e. the age at which children can consent to the processing of their personal data) from 13, as it currently is; restricting access to services based on the presence of particular features and functionalities which are age-inappropriate or too risky (such as livestreaming, ability to send and receive nude images and videos, location sharing, stranger pairing and disappearing messages); age restricting access to addictive features such as infinite scrolling, affirmation features and content recommendation algorithms; “curfews” to limit time children can spend on individual apps; and age restrictions on access to chatbots 
• defining the services that any restrictions should apply to – it is recognised that the term “social media” has no specific meaning in law, and that gaming sites and messaging services raise many of the same concerns as “social media” – and in particular whether the UK should look to follow the Australian model
• appropriate and effective age assurance tech to ensure compliance with, and enforcement of, any new laws
• whether DfE guidance on mobile phones in schools should be given statutory standing
• preparing children for a digital future through support with media and digital literacy skills, promotion of high quality content, and effective use of parental controls

Consultation closes on 26 May 2026, and the Government has committed to act quickly by responding with the consultation outcome this summer. Tech companies and other organisations providing online services that fall within the scope of this wide-ranging review should respond with their views, and should keep abreast of the direction of travel of the possible outcomes from the consultation. It is likely that this consultation will lead to new laws which will impact directly and significantly on the business models, features and functionalities, and technical access to and operation of in-scope services.

ESG: final UK Sustainability Reporting Standards published

On 25 February 2026, the Department for Business and Trade (DBT) published the final UK Sustainability Reporting Standards (UK SRS), based on the first two Sustainability Disclosure Standards issued by the International Sustainability Standards Board in June 2023 (ISSB Standards). The publication represents a significant step in creating a consistent, internationally aligned sustainability reporting framework for UK companies.

UK SRS are available for voluntary use now. The Government will consult later in 2026 to determine which entities will need to apply the standards and when.  

Background to UK SRS

Two standards have been published: (1) UK SRS S1: General Requirements for Disclosure of Sustainability-related Financial Information and (2) UK SRS S2: Climate-related Disclosures.  

UK SRS S2 builds on the existing Taskforce on Climate-related Financial Disclosures (TCFD) framework, which has applied to certain UK companies since 2021. Unlike TCFD, UK SRS S1 requires broader disclosure of sustainability related financial information.

For further detail on the key amendments to the ISSB Standards see our briefing: UK: Final UK Sustainability Reporting Standards published.

Next steps and actions

UK SRS sits within the broader Modernising Corporate Reporting (MCR) programme, under which the Government will consider making UK SRS reporting mandatory for larger private entities not subject to FCA regulation. The Government intends to consult further on its MCR programme later in 2026. The Government aims to balance simpler reporting requirements with the benefits of enhanced sustainability disclosures. 

Separately, the FCA is currently consulting on amendments to the UK Listing Rules to require in-scope listed entities to report climate-related information under UK SRS S2 (excluding Scope 3 emissions) on a mandatory basis, with Scope 3 emissions and non-climate sustainability matters subject to "comply or explain" reporting. Phased implementation is proposed from 1 January 2027.

Companies in the UK should now:

• Consider whether, to meet investor expectations and help streamline reporting obligations to lenders, financial sponsors and customers, they should adopt the standards voluntarily ahead of becoming subject to mandatory requirements. This may also be helpful to achieve global consistency.
• Carry out a gap analysis against their current climate and sustainability reporting (including the EU Corporate Sustainability Reporting Directive, where applicable) to highlight where additional data, systems, processes and governance will be required to report against UK SRS.
• Monitor developments with the Government's wider MCR programme, which may result in mandatory UK SRS reporting for economically significant private entities.
• Plan for future audit and assurance of disclosures (which is likely to emerge as an expectation). 

The publication of UK SRS marks a significant step in the shift towards globally consistent sustainability reporting. Early planning will help companies manage data and governance challenges and integrate sustainability related information more effectively into financial reporting.

With thanks to Phil Spyropoulos, Sarah Turner and Thomas Pritchard

How statutory warranty laws differ across jurisdictions

How statutory warranty laws differ across jurisdictions: understanding the differences between statutory warranty regimes for B2B sales agreements across key European jurisdictions.

When supplying goods across borders, statutory warranty rules may affect your risk exposure, customer obligations and the enforceability of contractual limitations. Although warranty regimes across European countries seem similar at first sight, each jurisdiction imposes different warranty provisions in the B2B context. Other than for consumer law, generally no EU laws regulate this field.

Whenever a company operates via distribution models, delivers or purchases goods cross border or negotiates pan European supply agreements, understanding these differences can be helpful. Depending on the governing law and type of contract, mandatory warranty provisions may override or supplement your negotiated terms, limit your ability to exclude liability, or impose specific repair and replace obligations – or apply per se if nothing is agreed on to deviate from the statutory concepts. Hence choosing the governing law for your contract might be just as important as the contractual provisions themselves and can determine whether it is advisable for you to divert from statutory provisions by agreement.

While the individual circumstances always matter, several jurisdictions offer stricter or more seller-friendly frameworks than others. For a high level overview of the statutory warranty landscape applicable for the sale of movable, non-digital goods in a B2B context across Germany, UK, France, Belgium, Romania, Czech Republic, Switzerland, Austria, Italy, Netherlands, and Ireland, see How statutory warranty laws differ across jurisdictions.

Key considerations to take away

Depending on whether you are selling or purchasing goods, it is worth assessing the specific statutory warranty provisions of jurisdictions where a governing law can be chosen for your contractual relationship. Sellers may favour legal systems allowing greater limitation or exclusion of warranty obligations, while buyers might prefer jurisdictions with stricter or more structured statutory protections. Hence, reviewing the length of warranty periods, burden of proof rules, notice requirements, and the availability of remedies is essential for understanding where the risk profile best aligns with the business model. Equally important is deciding whether to rely on statutory provisions or consciously depart from them through mutual agreement.

With thanks to Beatrice Bigonzi, Edward M. Tompkin-Haag, Maarten Stassen, Manuel Boka, Olaf van Haperen, Dr. Tobias Maier, Brian Connolly, Irina Stoicescu, Ondrej Sudoma, Chloe Charbeaux and Marius Kunderer