Who this is for: Trust Architects focused on policy-to-implementation translation, particularly those working on UNTP-aligned traceability, Digital Product Passports, and interoperability challenges emerging at the intersection of regulation, standards, and operational systems.
As 2025 turned into 2026, policy intent collided with the reality of real-world delivery and pushback. Frameworks may be delayed or even diluted, but transparency requirements are still increasing. Regulated or not.
Through it all, practitioners continue building the infrastructure required to make traceability and sustainability data usable and interoperable at scale.
Transparency pressures rising
Some sustainability reporting obligations face delivery uncertainty
In recent months, media coverage and debate in parts of Europe, has focused on simplifying, delaying, or narrowing sustainability and due diligence reporting obligations, especially for SMEs and mid-sized firms.
For example, the EU's anti-deforestation regime has faced delays and scope changes, with critics arguing that key obligations have been weakened and implementation clarity has declined.
In December, European Parliament and Council reached a provisional agreement to simplify reporting obligations under the EU's sustainability reporting (CSRD) and supply-chain due diligence (CSDDD) rules, considering proposals to narrow scope and reduce burdens.
Of course, sustainability reporting and regulatory requirements continue to evolve and roll out in Europe and around the world. For example, as noted in this sustainability law trends piece from DLA Piper:
- Sustainability reporting standards for listed companies became effective in Hong Kong and Pakistan in summer 2025.
- Australia's mandatory climate reporting regime is rolling out in phases based on company size, with the next group's reporting periods beginning in mid-2026 (for reports typically due the following year).
- Mandatory sustainability reporting standards are set to take effect in Chile and Japan in early 2026.
Why it matters: Whether sustainability rules tighten or are simplified, the core responsibility for Trust Architects is the same. Claims still need to be proven, challenged, reused, and reinterpreted by regulators, buyers, auditors etc.
Trust Architects will still need to design data, provenance, and verification approaches that can be reused across different regimes and assurance contexts, without having to rebuild everything each time the rules change.
Border and customs digitisation outpacing data readiness
Customs and border authorities continue to digitise processes, risk profiling, and pre-arrival data requirements, driven by a range of influences including geopolitical instability, evolving tariff regimes, and increased use of automated risk management. This raises expectations for structured, digitised information about goods, origin, and compliance status.
Why it matters: Supply-chain digitisation efforts are widely underway, to varying degrees. But organisations that struggle to keep up with border systems will end up relying on fragile integrations and manual fixes. Trust Architects, this means designing verification approaches that work across borders without having to build one-off solutions for every authority or market.
This is precisely why shared frameworks like the UN Transparency Protocol matter. It supports a common, interoperable foundation that can keep pace with evolving regulations, market access requirements and more without forcing bespoke integrations for each change.
Momentum signals: UNTP and interoperability are being pulled into practical work
UNECE: interoperability is being treated as a systems problem
UNECE's "Driving interoperability" update highlights that challenges such as sustainability and traceability cannot be solved through reporting alone. We don't have to tell you that reports abound, but the same things are identified differently across systems, the same concepts mean different things across sectors, data cannot be reused without transformation, and governance rules are often implicit rather than explicit. Alignment is required across data models, semantics, exchange mechanisms, and governance layers.
It's great to see UNECE continuing to recognise that fragmentation is a structural risk and validating a systems-level approach.
UNECE ESG traceability is moving toward sector pilots
The December 2025 UNECE/UN/CEFACT Team of Specialists on ESG Traceability session marked a shift from coordination toward use cases. 2026 workstreams were outlined across textiles, critical minerals, and agri-food sectors at risk of deforestation.
Of note:
- The focus is moving away from high-level principles toward defined, sector-specific, use-case driven work intended to result in pilots and demonstrations in 2026.
- Multiple sectors are converging on the same blockers, including fragmented systems, unclear data ownership, and misaligned incentives
- UNTP is referenced as an alignment layer, particularly in deforestation-risk discussions
Traction signals: adoption and implementation emerging in the real world
It is encouraging to see organisations starting to embed UNTP into their work and publicly signal that alignment. Here are two examples:
- Wholechain, a US-based supply chain traceability platform, has publicly stated that UNTP is one of its top priorities, in the context of the December 2025 UNECE/UN/CEFACT ESG Traceability session.
- You can find a list of software providers that have registered their intention to work with the UNTP here: UNTP Implementation Register
Note: These examples are shared to highlight emerging UNTP alignment and invite conversation, rather than as endorsements. Organisations working on related interoperability, traceability, and digital trust challenges are welcome to explore Trust Architecture and participate in the Trust Architect Community via our Pyx Pulse newsletter and chat.pyx.io.
Ecosystem signal: organisational identity and wallets are converging with Trust Architecture
The European Commission has published a proposal for European Business Wallets, positioning it as a cross-border digital business capability to reduce administrative burden and standardise business identity and compliance interactions.
FIDES, a European community and collaboration initiative focused on digital identity, organisational wallets, and trust infrastructure, has offered commentary on the emerging European Business Wallet framework. It positions organisational wallets, mandates/authority, verifiable credentials, and "trust anchors" (including references to UNTP/GRID) as core building blocks for how organisations prove who they are and who can act on their behalf.
Why it matters:
- Organisational wallets and mandate models are rapidly becoming the "missing layer" between technical endpoints and accountable entities.
What to watch next
- Keep an eye out for the UNTP public review in Q1 2026. It'll be a practical participation window for Trust Architects.
- Watch for the textiles, critical minerals, and agri-food sectors at risk of deforestation convening in 2026. This is where interoperability decisions are likely to get tested and shaped in practice.
- Look out for implementation proof points and share them with the community at chat.pyx.io.
Join the discussion
We've opened a Policy & Momentum Watch - Jan 2026 thread on chat.pyx.io so the Trust Architect Community can weigh in.
For those who want to go deeper, we'll share a reading list in the thread covering the developments referenced above, including EU deforestation rules, sustainability reporting simplification pressures, and border and customs digitisation.
Ask questions, add sources, or share what you're seeing on the ground. If there are policy shifts, pilots, or implementation signals you're tracking, we'd be keen for you to bring them into the conversation.