Our ESG timeline sets out recent and expected UK and EU legal and regulatory developments relating to ESG and wider sustainable business topics. The timeline can be filtered according to your business type or the relevant ESG theme.
The timeline will be maintained. The last major update was in February 2025. For a comprehensive overview, view our ESG Timeline Archive from 2021, 2022, and 2023.
Note on filters: The filters select the key obligations which are specifically relevant for that business category but additional obligations may apply to a particular business based on its size, structure or activities. For example, some of the obligations listed under Larger Businesses may be relevant to other business types, such as Listed Companies, depending on business size.
2024
As well as looking at potential options for refreshing and rationalising the current framework on non-financial reporting requirements, the review will also consider the size thresholds in the Companies Act 2006, which principally derive from EU legislation. Further to a call for evidence published in May 2023, the Government aims to develop detailed proposals for consultation in 2024.
In scope: All companies under the scope of the Companies Act 2006
Theme: Sustainable finance and ESG reporting
The Environmental Taxonomy Delegated Act introduces the technical screening criteria relevant for determining whether the relevant economic activity contributes substantially to one of the four remaining environmental objectives under the EU Taxonomy Regulation (Water and Marine Resources, Circular Economy, Pollution Prevention and Biodiversity and Ecosystems) and whether the activity causes no significant harm to the other objectives.
In scope: Financial markets participants, issuers of financial products and large public interest entities
Theme:
Companies may voluntarily apply the ISSB's first sustainability standards, IFRS S1 and S2 to make investor-facing sustainability disclosures on a voluntary basis (until mandated by regulation).
In scope: All business organisations
Theme: Sustainable finance and ESG reporting
Delegated Regulation amending the technical screening criteria for the environmental objectives of climate change mitigation and adaptation applies.
In scope: Financial markets participants, issuers of financial products and large public interest entities
Theme:
EU Taxonomy Regulation – Additional requirements under Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 applies.
In scope: Large financial public interest entities
Theme: Climate change, environment and resources
Application of EU Corporate Sustainability Reporting Directive to large EU Public Interest Entities ("PIEs"); sustainability reporting in 2025 for FY beginning on or after 01-01 2024.
In scope: PIEs and any entities already covered by the Non-Financial Reporting Directive
Qualifying conditions: Number of employees: ≥500
Theme: Sustainable finance and ESG reporting
The Taskforce on Social Factors, set up by the Government, published a guide on Considering Social Factors in Pension Scheme Investments.
In scope: Pension trustees
The Pensions Regulator's General Code of Practice is in force and includes new content on scheme governance, broadening existing internal controls requirements to require occupational pension schemes to "establish and operate an effective system of governance including internal controls", which must be "proportionate to the size, nature, scale and complexity of the activities of the occupational pension scheme".
In scope: Pension scheme trustees with 100 or more members in their scheme
The UK's Environment Act 2021 will require all new small real estate developments to deliver a 10% 'biodiversity net gain' from April 2024, which will effectively become a requirement of its planning permission. This can be delivered through on-site or off-site measures, buying statutory credits or a combination.
Small sites are defined as follows:
(i) for residential schemes: one to nine dwellings on a site of less than one hectare, or where the number of dwellings is unknown, a site area of less than 0.5 hectares.
(ii) for commercial sites, a scheme of under 1,000 square metres OR where the site area is less than one hectare.
In scope: All businesses developing real estate in the UK
Theme: Built Environment
FCA's anti-greenwashing rules and associated guidance come into effect.
In scope: FCA authorised firms
Original deadline for publication of first sector-specific reporting standards under the Corporate Sustainability Reporting Directive - subsequently delayed by 2 years.
In scope:
Theme: Sustainable finance and ESG reporting
The UK's Energy Savings Opportunity Scheme requires businesses to periodically audit their energy use and identify (and cost) potential energy savings by 5 December 2023, extended to 5 June 2024 and with a further enforcement stay to 6 August 2024.
In Scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
Theme: Climate change, environment and resources
Additional deadline for UK-authorised asset managers with in-scope assets ≥£5bn and asset owners with In-scope assets between £5bn and £25bn to make climate-related financial disclosures consistent with TCFD Recommendations.
In Scope: Additional UK-authorised asset managers and asset owners.
Theme: Sustainable finance and ESG reporting
Corporate Sustainability Reporting Directive.
In scope:
Listed companies which are public interest entities ("PIEs");
Larger non-listed companies (ie. any non-listed company which is not an SME under the Accounting Directive);
Listed SMEs (except micro-enterprises);
Some financial institutions;
Non-EU companies with significant turnover in the EU.
Sustainability labels as set out in the FCA rules become available for products that invest in accordance with a sustainability objective. Associated disclosure and distribution requirements start to apply.
In scope: UK fund managers and distributors
The Environment Agency stay of enforcement in respect of the Energy Savings Opportunity Scheme phase 3 notification of compliance expires
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
The UK Government has introduced a positive duty on employers to prevent workplace sexual harassment, including harassment of staff by third parties.
In scope: All businesses
The UK Government is currently consulting on a market framework for the regulation of heat networks, including general authorisations, zoning and other protections. This is intended to increase the development and up-take of heat networks.
In scope: All businesses developing real estate in the UK
Theme: Built environment
The LMA launched draft provisions for Green Loans – standardised riders (optimised for insertion into a loan agreement) where green loans are to be advanced as part of a facility.
In scope: Lenders
The EU Directive on Adequate Minimum Wage establishes procedures for the adequacy of statutory minimum wages, promotes collective bargaining on wage setting and improves protections for workers who are entitled to a minimum wage under national law
In scope: All business organisations operating in the EU
Theme: People
ESMA guidelines on the use of ESG or sustainability-related terms in funds' names start to apply. Transitional period for existing funds until 21 May 2025.
In scope: EU fund managers
Naming and marketing rules (with associated disclosure requirements) as set out in the FCA rules start to apply in relation to non-labelled products with ESG terms.
In scope: UK fund managers and distributors
First ESOS Action Plan, describing energy efficiency measures planned for implementation during the year, to be registered in the MESOS registry – deadline was extended.
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
Parker ethnic diversity target for FTSE 250: The target date for companies to meet the Parker Review aim of there being at least one director of colour from a minority ethnic background on each FTSE 250 board by 2024. Listed companies now required to state whether they have met this requirement, by UKLR6.6.6(9).
In scope: Listed companies – FTSE 250
Theme: People
01 January 2025
Application of CSRD to large EU companies; sustainability reporting in 2026 for FY beginning on or after 01-01-2025. Omnibus proposes to delay reporting by 2 years.
In scope:
Large companies not previously covered by the Non-financial Reporting Directive (ie. any company which is not an SME under the Accounting Directive)
In each case, satisfying at least two of the three size criteria
Qualifying conditions:
Theme: Sustainable finance and ESG reporting
2025
The Future Buildings Standard, which will set out more stringent efficiency standards, to ensure that new non-domestic buildings are zero carbon ready from 2025, is expected to be implemented at some point in 2025 (precise date to be confirmed) for all new non-domestic developments.
In scope: All businesses developing real estate in the UK
Theme: Built environment
In scope: All businesses operating in the EU
Qualifying condition: Turnover greater than or equal to EUR 150m in the EU
Theme: Climate change, environment and resources,
Built environment
2025 and 2026
Revised UK Corporate Governance Code and new accompanying guidance to take effect for accounting periods beginning on or after 1 January 2025, save that the new provision requiring an annual board declaration on the company's risk management and internal control framework will apply for accounting periods beginning on or after 1 January 2026. See our briefing of the proposed changes.
In scope: Companies with a listing on the equity shares (commercial companies) category ("ESCC") of the Official List.
Proposals published to delay reporting by CSRD "Wave 2" (large) companies and groups, and listed SMEs, and separately, proposing broader changes to CSRD and CS3D (as well as Taxonomy Regulation)
In scope: All business organisations of a certain size operating in the EU, and SMEs listed on EU regulated markets
Extended deadline by which companies' first ESOS Action Plan, describing energy efficiency measures planned for implementation during the year, must be registered in the MESOS registry
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
LMA SLL Principles
The Loan Market Association published market template sustainability-linked loan principles, together with related guidance
In scope: Lenders and borrowers
Quarter 1 2025
UK Government plans to launch a consultation on adopting ISSB sustainability standards, IFRS S1 and IFRS S2 as UK sustainability reporting standards.
In scope: All business organisations
The Loan Market Association and International Capital Market Association published Guidelines for Sustainability-Linked Loans financing bonds, with FAQs
In scope: Lenders and borrowers
Entities placing certain products (raw materials including wood, coffee and soya, as well as finished products such as chocolate and tyres) on the EU market will need to prove that they have conducted appropriate due diligence to ensure that products are "deforestation-free" and produced in compliance with the laws of the country of origin.
In scope: "Operators" first placing products on the market and "traders" making products available on the market.
Qualifying conditions:
The new strict liability offence of failing to prevent fraud comes into effect in the UK, under the Economic Crime and Corporate Transparency Act 2023. See our briefing for more details on what is "fraud" for these purposes, who is in scope and how to establish a defence.
Businesses should note that the new offence sits alongside and overlaps with the existing offence of failure to prevent the facilitation of tax evasion (on which further information can be found here). In relation to tax, it is therefore advisable to ensure that policies and procedures cover both offences and are regularly reviewed.
In scope: Large organisations as defined in s201 of ECCTA
Qualifying conditions:
The Government's consultation on how to introduce climate-related transition plans that align with the 1.5°C goal of the Paris Agreement for a range of UK-regulated financial institutions, closed on 17 September 2025 and a response is awaited.
The DWP will be reviewing the pension scheme climate change governance and reporting regulations, building on evidence provided by the Pensions Regulator.
In scope: UK regulated financial institutions including banks, asset managers, pension funds and insurers and FTSE100 companies.
October 2025
The Loan Market Association launched a new Guide to "transition finance", explaining how it can be integrated into existing financial instruments.
In scope: Lenders and borrowers
Entity-level disclosures including a public report on approach to sustainability-related risks and opportunities.
In scope: UK fund managers with AUM of £50 billion or more.
On demand product-level sustainability information requests become available.
In scope: UK fund managers
First annual update to the phase 3 action plan to be filed in the MESOS registry.
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
"Stop-the-Clock" directive and delays to reporting requirements were to take effect in Member States by this date
In scope: "Large" undertakings and groups within the meaning of CSRD, and listed SMEs (or other PIE SMEs)
FTSE Women Leaders report of 2022 recommends that by end of 2025:
In scope: Listed companies: FTSE 350
2026 (TBC)
The Commission is expected to adopt delegated acts adopting revised cross-sector reporting standards under CSRD, proposed by EFRAG in late 2025
In scope: All entities in scope of the CSRD
The Government announced in December 2025 that it will be consulting on statutory guidance to give trustees clarity that when investing in members' best interests, they may take into account broader systemic risks and opportunities to their investments, the positive (and negative) impacts of investments (including impacts on members’ standards of living) and the ability, where appropriate, to take account of members' views.
In scope organisations: Pension scheme Trustees
2026
The European Parliament has approved an AI Act to harmonise AI rules across the EU, which covers AI systems used by employers in the EU. Most of the provisions of the Act are expected to come into force in 2026.
Several Taxonomy-related regulations amended as part of Omnibus package. Key simplifications include (a) an exemption for financial and non-financial companies from assessing taxonomy-eligibility/alignment for activities that are not financially material, (b) an exemption from assessing taxonomy alignment for non-financial companies re: OpEx when non-material, (c) simplified KPIs for financial companies in certain circumstances and (d) simplified DNSH criteria re: pollution prevent and control related to use and presence of chemicals
In scope: Financial markets participants, issuers of financial products and large public interest entities in scope of the Disclosure Regulations
Application of CSRD to listed SMEs; sustainability reporting in 2027 for FY beginning on or after 01 January 2026 but can optionally be postponed for 2 years. Omnibus would postpone the deadline by 2 years.
In scope: Listed SMEs (except micro-enterprises)
April 2026
Large employers will be required to produce an equality action plan setting out the steps they are taking to reduce their gender pay gap and how they support employees through the menopause. This is voluntary from April 2026 and will be compulsory from 2027.
In scope: Employers with 250 or more employees.
Agencies or end clients to be made responsible for operating PAYE on workers provided through umbrella companies. TBC but probably through ITEPA and PAYE regulations.
In scope: All business organisations
The PRA's updated supervisory statement (SS5/25) requires in-scope PRA-regulated firms to have completed internal reviews of whether they are meeting the updated expectations for managing climate risk in the supervisory statement by this deadline.
The expectations relate primarily to risk assessment and risk management capabilities to build better resilience against climate change.
In scope: UK insurers, reinsurers, banks, building societies and PRA-designated investment firms
The EU Directive on equal pay and pay transparency introduces various measures to improve equal pay enforcement and transparency. EU member states are required to implement the Directive by 7 June 2026.
Under the Directive, employers in EU member states with at least 250 employees will be required to publish gender pay gap information annually, and employers with at least 150 employees (dropping to 100 employees from 2030) will have to publish information every 3 years. The Directive also introduces measures relating to pay transparency in recruitment and promotion.
In scope: Organisations with at least 150 employees
Qualifying conditions:
At least 40% of non-executive directors (or 33% of all directors) on the boards of large EU incorporated listed entities to be women, by 30 June 2026.
Applies where both employee threshold and one of the financial thresholds are met.
In scope: Large listed companies
Qualifying condition:
Theme: People
EU Deforestation Regulation applies to micro and small companies – those meeting 2 of the 3 thresholds for turnover, balance sheet or employees (deadline extended from 30 June 2025).
In scope: Large listed companies
Qualifying condition:
EU Regulation on ESG rating activities to apply with rules on the activities of ESG ratings providers.
In scope: ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications.
EU Regulation on ESG rating activities – transitional provision imposing a deadline on ESG rating providers (other than small ESG rating providers) that were in operation on 2 January 2025 to notify ESMA if they want to continue offering their services and apply for authorisation/ recognition. A ratings provider will be "small" if it does not exceed two of the three qualifying conditions below
In scope: ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications (exceeding at least two of the three qualifying conditions)
Qualifying conditions:
EU Energy Efficiency Directive 2023/1791 revises the energy audit requirement (equivalent to UK ESOS) and introduces a requirement for an energy action plan which must be published in the annual report. The new requirements will be prescribed by national Member State law.
In scope: Businesses with average annual consumption of 10TJ or more over the previous 3 years with operations in EU Member States
EU Regulation on ESG rating activities – transitional provision imposing a deadline on ESG rating providers (other than small ESG rating providers) that were in operation on 2 January 2025 to apply for authorisation/ recognition failing which they must cease their activities. A ratings provider will be "small" if it does not exceed two of the three qualifying conditions below
In scope: ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications (exceeding at least two of the three qualifying conditions)
Qualifying conditions:
Theme: Sustainable finance and ESG reporting
EU Regulation on ESG rating activities – transitional provision imposing a deadline on small ESG rating providers that were in operation on 2 January 2025 to notify ESMA if they want to continue offering their services, failing which they must cease their activities. A ratings provider will be "small" if it does not exceed two of the three qualifying conditions below
In scope: Small ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications
Qualifying conditions:
Theme: Sustainable finance and ESG reporting
Entity-level disclosures including a public report on approach to sustainability related risks and opportunities.
In scope: UK fund managers with AUM between £5 billion and £50 billion.
EU Deforestation Regulation applies to large and medium companies (deadline extended twice from 30 December 2024 and then December 2025)
In scope: Large and medium enterprises as defined in the Accounting Directive
Qualifying conditions:
Companies must assess whether they fall into scope of the Energy Savings Opportunity Regulations (Phase 4) which requires energy audits to be carried out. Large employers will be required to report on ethnicity and disability pay gaps, and also publish an equality action plan, setting out how they will reduce their gender pay gap and support employees through the menopause
In scope: Large undertakings (those meeting either the employee or both financial thresholds), and groups containing large undertakings.
Qualifying conditions:
2027
Large employers will be required to report on ethnicity and disability pay gaps. Large employers will also be required to produce an equality action plan setting out the steps they are taking to reduce their gender pay gap and how they support employees through the menopause.
In scope: Employers with 250 or more employees.
2027
Zero hours and minimum hours workers (including agency workers) will have a new right to be offered a regular hours contract if their working hours regularly exceed the zero/ minimum hour level over a set reference period. There will also be a right to reasonable notice of shifts and compensation if shifts are cancelled or curtailed
In scope: All organisations engaging workers on zero / minimum hour contracts or irregular hours workers.
Proposed introduction of mandatory reporting by listed companies in accordance with UK sustainability reporting standards based on ISSB standards, for financial years beginning on or after this date
In scope: Listed companies
Revised date for application of CSRD to large EU companies/groups; sustainability reporting in 2028 for FY beginning on or after 01-01-2027.
In scope: Large companies not previously covered by the Non-financial Reporting Directive (ie. any company which is not an SME under the Accounting Directive) In each case, satisfying at least two of the three size criteria
Qualifying condition: Turnover greater than or equal to EUR 50m, Number of employees greater than or equal to 1000.
EU Deforestation Regulation applies to micro and small companies – those meeting 2 of the 3 thresholds for turnover, balance sheet or employees (deadline extended from 30 June 2025)
In scope: Small and micro enterprises as defined in the Accounting Directive
Qualifying conditions:
Extended deadline for Commission to adopt limited assurance standards under the CSRD (previously 1 October 2026)
In scope: All entities in scope of the CSRD
Application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies Omnibus proposes to delay this deadline by one year.
In scope:
"Group 1": Certain of the largest EU companies and groups;
"Group 2": Certain of the largest non-EU companies with turnover in the EU
Qualifying conditions:
Omnibus proposal would change the deadline for transposition by Member States and extend it by one year.
In scope:
"Group 1": Certain of the largest EU companies and groups;
"Group 2": Certain of the largest non-EU companies with turnover in the EU
Qualifying condition:
Group 1: greater than EUR 450m net worldwide turnover
Group 2: greater than EUR 450m net turnover in the EU
Entities in scope of Phase 4 of ESOS must notify their compliance by this date
In scope: Large undertakings (those meeting either the employee or both financial thresholds), and groups containing large undertakings
Qualifying conditions:
Businesses placing or making available products on the EU market must ensure they are not made with forced labour. They must be able to demonstrate to competent authorities on request that they have taken appropriate steps to identify, prevent, mitigate or bring to an end the risk of forced labour in their operations and value chain, via due diligence.
In scope: Economic operators placing or making products available on the EU market
The 2023 update report to the Parker review recommends that FTSE 350 companies set a percentage target for senior management positions (for this purpose, members of the executive committee and senior managers who report directly to them) that will be occupied by ethnic minority executives in December 2027.
In scope: FTSE 350 companies
2028 (TBC)
Potential date for the updated EU SFDR framework (known as SFDR 2.0) to begin to apply.
This is currently a legislative proposal and may therefore be subject to significant changes.
It is expected to introduce a replacement product categorisation framework which will specify new criteria for different categories of sustainable finance products and regulate permitted sustainability-related claims in marketing and investor disclosure and reporting communications relating to them.
The new categories will include Article 7 (Transition), Article 8 (ESG Basics) and Article 9 (Sustainable) products. There will also be updated criteria which will determine when a product does not fall within the categories of sustainability-related products (Article 6a).
In scope:
EU providers of financial products and non-EU financial product providers marketing products in the EU.
This includes fund managers, pension product providers and providers of insurance-based investment products.
Revised date of application of CSRD to listed SMEs; however, under the agreed Omnibus text, listed SMEs will no longer be in scope
In scope: Listed SMEs (except micro-enterprises)
Theme: Sustainable finance and ESG reporting
Application of EU Corporate Sustainability Reporting Directive to non-EU companies; sustainability reporting in 2029 for FY beginning on or after 01-01-2028.
In scope: Non-EU companies with significant turnover in the EU and an EU subsidiary, or a branch with EUR200m turnover
Qualifying condition: Turnover greater than or equal to EUR 450m in the EU
Application date for the new UK regulated activity of providing an ESG rating.
Broadly, this will apply where a person provides an ESG rating (whether solicited or not) which is likely to influence an investment decision, and the person could reasonably have expected it to do so.
An ESG rating is an assessment regarding one or more ESG factors which is in the form of a score or opinion (or both) and is prepared using an established methodology and a defined ranking system.
Various exemptions apply.
In scope: Entities providing non-exempt ESG ratings
Omnibus Directive provided one extra year for transposition by Member States (already extended by one year by the Stop The Clock Directive)
In scope:
Group 1": Certain of the largest EU companies and groups;
"Group 2": Certain of the largest non-EU companies with turnover in the EU
"Group 3": certain EU and non-EU companies/groups who entered into large franchising or licensing agreements in the EU
Qualifying conditions:
Number of employees:
Application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies.
In scope:
"Group 1": Certain very large EU companies/ groups.
"Group 2": Certain very large non-EU companies/ groups
Qualifying conditions:
Companies in scope of the Corporate Sustainability Due Diligence Directive are required to publish their first annual due diligence statements for financial years beginning on or after 1 January 2030
In scope: All entities in scope of the CS3D
01 January 2030 (TBC)
Regulations expected to be introduced to provide that all rented non-domestic buildings must achieve EPC Band B, where cost-effective. This may involve introducing a performance-based rating scheme for large commercial and industrial buildings to provide investors and their tenants with more information on how to reduce energy consumption and lower both carbon emissions and energy bills.
In scope: All business organisations
EU Commission's proposed revisions to the Energy Performance of Buildings Directive (EPBD) intend to require all new buildings to be zero-emission as of 2030.
In scope: All business organisations developing real estate in the EU
TBC
The UK Labour government included a commitment in its 2024 manifesto to mandate regulated UK financial institutions and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5° Paris Agreement goal.
Although it published a consultation in June 2025 setting out potential approaches, the proposals to implement this commitment have not yet been confirmed
In scope: UK regulated financial institutions, FTSE 100 companies
TBC
UK Government to amend the Environment Act to introduce due diligence requirements for larger businesses to prevent forests and natural areas from being converted illegally into agricultural land.
In scope: Larger businesses (based on turnover test to be confirmed) – subject to de minimis threshold for volume of commodity used
Minimum Energy Efficiency Standard Regulations
In scope: All business organisations which own let residential units.
2024
As well as looking at potential options for refreshing and rationalising the current framework on non-financial reporting requirements, the review will also consider the size thresholds in the Companies Act 2006, which principally derive from EU legislation. Further to a call for evidence published in May 2023, the Government aims to develop detailed proposals for consultation in 2024.
In scope: All companies under the scope of the Companies Act 2006
Theme: Sustainable finance and ESG reporting
The Environmental Taxonomy Delegated Act introduces the technical screening criteria relevant for determining whether the relevant economic activity contributes substantially to one of the four remaining environmental objectives under the EU Taxonomy Regulation (Water and Marine Resources, Circular Economy, Pollution Prevention and Biodiversity and Ecosystems) and whether the activity causes no significant harm to the other objectives.
In scope: Financial markets participants, issuers of financial products and large public interest entities
Theme:
Companies may voluntarily apply the ISSB's first sustainability standards, IFRS S1 and S2 to make investor-facing sustainability disclosures on a voluntary basis (until mandated by regulation).
In scope: All business organisations
Theme: Sustainable finance and ESG reporting
Delegated Regulation amending the technical screening criteria for the environmental objectives of climate change mitigation and adaptation applies.
In scope: Financial markets participants, issuers of financial products and large public interest entities
Theme:
EU Taxonomy Regulation – Additional requirements under Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 applies.
In scope: Large financial public interest entities
Theme: Climate change, environment and resources
Application of EU Corporate Sustainability Reporting Directive to large EU Public Interest Entities ("PIEs"); sustainability reporting in 2025 for FY beginning on or after 01-01 2024.
In scope: PIEs and any entities already covered by the Non-Financial Reporting Directive
Qualifying conditions: Number of employees: ≥500
Theme: Sustainable finance and ESG reporting
The Taskforce on Social Factors, set up by the Government, published a guide on Considering Social Factors in Pension Scheme Investments.
In scope: Pension trustees
The Pensions Regulator's General Code of Practice is in force and includes new content on scheme governance, broadening existing internal controls requirements to require occupational pension schemes to "establish and operate an effective system of governance including internal controls", which must be "proportionate to the size, nature, scale and complexity of the activities of the occupational pension scheme".
In scope: Pension scheme trustees with 100 or more members in their scheme
The UK's Environment Act 2021 will require all new small real estate developments to deliver a 10% 'biodiversity net gain' from April 2024, which will effectively become a requirement of its planning permission. This can be delivered through on-site or off-site measures, buying statutory credits or a combination.
Small sites are defined as follows:
(i) for residential schemes: one to nine dwellings on a site of less than one hectare, or where the number of dwellings is unknown, a site area of less than 0.5 hectares.
(ii) for commercial sites, a scheme of under 1,000 square metres OR where the site area is less than one hectare.
In scope: All businesses developing real estate in the UK
Theme: Built Environment
FCA's anti-greenwashing rules and associated guidance come into effect.
In scope: FCA authorised firms
June 2024
Original deadline for publication of first sector-specific reporting standards under the Corporate Sustainability Reporting Directive - subsequently delayed by 2 years.
In scope:
Theme: Sustainable finance and ESG reporting
The UK's Energy Savings Opportunity Scheme requires businesses to periodically audit their energy use and identify (and cost) potential energy savings by 5 December 2023, extended to 5 June 2024 and with a further enforcement stay to 6 August 2024.
In Scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
Theme: Climate change, environment and resources
Additional deadline for UK-authorised asset managers with in-scope assets ≥£5bn and asset owners with In-scope assets between £5bn and £25bn to make climate-related financial disclosures consistent with TCFD Recommendations.
In Scope: Additional UK-authorised asset managers and asset owners
Theme: Sustainable finance and ESG reporting
Corporate Sustainability Reporting Directive.
In scope:
Listed companies which are public interest entities ("PIEs");
Larger non-listed companies (ie. any non-listed company which is not an SME under the Accounting Directive);
Listed SMEs (except micro-enterprises);
Some financial institutions;
Non-EU companies with significant turnover in the EU.
Sustainability labels as set out in the FCA rules become available for products that invest in accordance with a sustainability objective. Associated disclosure and distribution requirements start to apply.
In scope: UK fund managers and distributors
The Environment Agency stay of enforcement in respect of the Energy Savings Opportunity Scheme phase 3 notification of compliance expires
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
The UK Government has introduced a positive duty on employers to prevent workplace sexual harassment, including harassment of staff by third parties.
In scope: All businesses
The UK Government is currently consulting on a market framework for the regulation of heat networks, including general authorisations, zoning and other protections. This is intended to increase the development and up-take of heat networks.
In scope: All businesses developing real estate in the UK
Theme: Built environment
The LMA launched draft provisions for Green Loans – standardised riders (optimised for insertion into a loan agreement) where green loans are to be advanced as part of a facility.
In scope: Lenders
The EU Directive on Adequate Minimum Wage establishes procedures for the adequacy of statutory minimum wages, promotes collective bargaining on wage setting and improves protections for workers who are entitled to a minimum wage under national law
In scope: All business organisations operating in the EU
Theme: People
ESMA guidelines on the use of ESG or sustainability-related terms in funds' names start to apply. Transitional period for existing funds until 21 May 2025.
In scope: EU fund managers
Naming and marketing rules (with associated disclosure requirements) as set out in the FCA rules start to apply in relation to non-labelled products with ESG terms.
In scope: UK fund managers and distributors
First ESOS Action Plan, describing energy efficiency measures planned for implementation during the year, to be registered in the MESOS registry – deadline was extended.
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
Parker ethnic diversity target for FTSE 250: The target date for companies to meet the Parker Review aim of there being at least one director of colour from a minority ethnic background on each FTSE 250 board by 2024. Listed companies now required to state whether they have met this requirement, by UKLR6.6.6(9).
In scope: Listed companies – FTSE 250
Theme: People
2025
The UK's Financial Conduct Authority (FCA) has consulted on a proposed new regulatory framework on diversity and inclusion in the financial sector. Non-financial misconduct will be incorporated into the FCA's Conduct Rules, and such misconduct will be expressly relevant for assessments of fitness and propriety for certified staff and regulatory references. Large firms will also be required to set diversity targets and report annually on certain diversity and inclusion matters.
In scope: FCA-regulated firms in the financial sector.
Application of CSRD to large EU companies; sustainability reporting in 2026 for FY beginning on or after 01-01-2025. Omnibus proposes to delay reporting by 2 years.
In scope:
Large companies not previously covered by the Non-financial Reporting Directive (ie. any company which is not an SME under the Accounting Directive)
In each case, satisfying at least two of the three size criteria
Qualifying conditions:
Theme: Sustainable finance and ESG reporting
2025
The Future Buildings Standard, which will set out more stringent efficiency standards, to ensure that new non-domestic buildings are zero carbon ready from 2025, is expected to be implemented at some point in 2025 (precise date to be confirmed) for all new non-domestic developments.
In scope: All businesses developing real estate in the UK
Theme: Built environment
In scope: All businesses operating in the EU
Qualifying condition: Turnover greater than or equal to EUR 150m in the EU
Theme: Climate change, environment and resources,
Built environment
2025 and 2026
Revised UK Corporate Governance Code and new accompanying guidance to take effect for accounting periods beginning on or after 1 January 2025, save that the new provision requiring an annual board declaration on the company's risk management and internal control framework will apply for accounting periods beginning on or after 1 January 2026. See our briefing previous briefing for details of the proposed changes.
In scope: Companies with a listing on the equity shares (commercial companies) category ("ESCC") of the Official List.
Proposals published to delay reporting by CSRD "Wave 2" (large) companies and groups, and listed SMEs, and separately, proposing broader changes to CSRD and CS3D (as well as Taxonomy Regulation)
In scope: All business organisations of a certain size operating in the EU, and SMEs listed on EU regulated markets
Extended deadline by which companies' first ESOS Action Plan, describing energy efficiency measures planned for implementation during the year, must be registered in the MESOS registry
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
LMA SLL Principles
The Loan Market Association published market template sustainability-linked loan principles, together with related guidance
In scope: Lenders and borrowers
Quarter 1 2025
UK Government plans to launch a consultation on adopting ISSB sustainability standards, IFRS S1 and IFRS S2 as UK sustainability reporting standards.
In scope: All business organisations
Entities placing certain products (raw materials including wood, coffee and soya, as well as finished products such as chocolate and tyres) on the EU market will need to prove that they have conducted appropriate due diligence to ensure that products are "deforestation-free" and produced in compliance with the laws of the country of origin.
In scope: "Operators" first placing products on the market and "traders" making products available on the market.
Qualifying conditions:
The new strict liability offence of failing to prevent fraud comes into effect in the UK, under the Economic Crime and Corporate Transparency Act 2023. See our briefing for more details on what is "fraud" for these purposes, who is in scope and how to establish a defence.
Businesses should note that the new offence sits alongside and overlaps with the existing offence of failure to prevent the facilitation of tax evasion (on which further information can be found here). In relation to tax, it is therefore advisable to ensure that policies and procedures cover both offences and are regularly reviewed.
In scope: Large organisations as defined in s201 of ECCTA
Qualifying conditions:
The Loan Market Association and International Capital Market Association published Guidelines for Sustainability-Linked Loans financing bonds, with FAQs
In scope: Lenders and borrowers
The Government's consultation on how to introduce climate-related transition plans that align with the 1.5°C goal of the Paris Agreement for a range of UK-regulated financial institutions, closed on 17 September 2025 and a response is awaited.
The DWP will be reviewing the pension scheme climate change governance and reporting regulations, building on evidence provided by the Pensions Regulator.
In scope: UK regulated financial institutions including banks, asset managers, pension funds and insurers and FTSE100 companies.
October 2025
The Loan Market Association launched a new Guide to "transition finance", explaining how it can be integrated into existing financial instruments.
In scope: Lenders and borrowers
Entity-level disclosures including a public report on approach to sustainability-related risks and opportunities.
In scope: UK fund managers with AUM of £50 billion or more.
On demand product-level sustainability information requests become available.
In scope: UK fund managers
First annual update to the phase 3 action plan to be filed in the MESOS registry.
In scope: All business organisations of a certain size operating in the UK
Qualifying conditions:
"Stop-the-Clock" directive proposed as part of the Omnibus package should take effect in Member States by this date
In scope: "Large" undertakings and groups within the meaning of CSRD, and listed SMEs (or other PIE SMEs)
FTSE Women Leaders report of 2022 recommends that by end of 2025:
In scope: Listed companies: FTSE 350
2026 (TBC)
The Commission is expected to adopt delegated acts adopting revised cross-sector reporting standards under CSRD, proposed by EFRAG in late 2025
In scope: All entities in scope of the CSRD
The Government announced in December 2025 that it will be consulting on statutory guidance to give trustees clarity that when investing in members' best interests, they may take into account broader systemic risks and opportunities to their investments, the positive (and negative) impacts of investments (including impacts on members’ standards of living) and the ability, where appropriate, to take account of members' views.
In scope organisations: Pension scheme Trustees
2026
The European Parliament has approved an AI Act to harmonise AI rules across the EU, which covers AI systems used by employers in the EU. Most of the provisions of the Act are expected to come into force in 2026.
Several Taxonomy-related regulations amended as part of Omnibus package. Key simplifications include (a) an exemption for financial and non-financial companies from assessing taxonomy-eligibility/alignment for activities that are not financially material, (b) an exemption from assessing taxonomy alignment for non-financial companies re: OpEx when non-material, (c) simplified KPIs for financial companies in certain circumstances and (d) simplified DNSH criteria re: pollution prevent and control related to use and presence of chemicals
In scope: Financial markets participants, issuers of financial products and large public interest entities in scope of the Disclosure Regulations
Application of CSRD to listed SMEs; sustainability reporting in 2027 for FY beginning on or after 01 January 2026 but can optionally be postponed for 2 years. Omnibus would postpone the deadline by 2 years.
In scope: Listed SMEs (except micro-enterprises)
Theme: Sustainable finance and ESG reporting
April 2026
Large employers will be required to report on ethnicity and disability pay gaps. Large employers will also be required to produce an equality action plan setting out the steps they are taking to reduce their gender pay gap and how they support employees through the menopause.
In scope: Employers with 250 or more employees.
Agencies or end clients to be made responsible for operating PAYE on workers provided through umbrella companies. TBC but probably through ITEPA and PAYE regulations.
In scope: All business organisations
The PRA's updated supervisory statement (SS5/25) requires in-scope PRA-regulated firms to have completed internal reviews of whether they are meeting the updated expectations for managing climate risk in the supervisory statement by this deadline.
The expectations relate primarily to risk assessment and risk management capabilities to build better resilience against climate change.
In scope: UK insurers, reinsurers, banks, building societies and PRA-designated investment firms
The EU Directive on equal pay and pay transparency introduces various measures to improve equal pay enforcement and transparency. EU member states are required to implement the Directive by 7 June 2026.
Under the Directive, employers in EU member states with at least 250 employees will be required to publish gender pay gap information annually, and employers with at least 150 employees (dropping to 100 employees from 2030) will have to publish information every 3 years. The Directive also introduces measures relating to pay transparency in recruitment and promotion.
In scope: Organisations with at least 150 employees
Qualifying conditions:
At least 40% of non-executive directors (or 33% of all directors) on the boards of large EU incorporated listed entities to be women, by 30 June 2026.
Applies where both employee threshold and one of the financial thresholds are met.
In scope: Large listed companies
Qualifying condition:
Theme: People
EU Deforestation Regulation applies to micro and small companies – those meeting 2 of the 3 thresholds for turnover, balance sheet or employees (deadline extended from 30 June 2025).
In scope: Large listed companies
Qualifying condition:
EU Regulation on ESG rating activities to apply with rules on the activities of ESG ratings providers.
In scope: ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications.
EU Regulation on ESG rating activities – transitional provision imposing a deadline on ESG rating providers (other than small ESG rating providers) that were in operation on 2 January 2025 to notify ESMA if they want to continue offering their services and apply for authorisation/ recognition. A ratings provider will be "small" if it does not exceed two of the three qualifying conditions below
In scope: ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications (exceeding at least two of the three qualifying conditions)
Qualifying conditions:
EU Energy Efficiency Directive 2023/1791 revises the energy audit requirement (equivalent to UK ESOS) and introduces a requirement for an energy action plan which must be published in the annual report. The new requirements will be prescribed by national Member State law.
In scope: Businesses with average annual consumption of 10TJ or more over the previous 3 years with operations in EU Member States
EU Regulation on ESG rating activities – transitional provision imposing a deadline on ESG rating providers (other than small ESG rating providers) that were in operation on 2 January 2025 to apply for authorisation/ recognition failing which they must cease their activities. A ratings provider will be "small" if it does not exceed two of the three qualifying conditions below
In scope: ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications (exceeding at least two of the three qualifying conditions)
Qualifying conditions:
Theme: Sustainable finance and ESG reporting
EU Regulation on ESG rating activities – transitional provision imposing a deadline on small ESG rating providers that were in operation on 2 January 2025 to notify ESMA if they want to continue offering their services, failing which they must cease their activities. A ratings provider will be "small" if it does not exceed two of the three qualifying conditions below
In scope: Small ESG ratings providers operating in the EU and certain financial entities which disclose ESG ratings in marketing communications
Qualifying conditions:
Theme: Sustainable finance and ESG reporting
Entity-level disclosures including a public report on approach to sustainability related risks and opportunities.
In scope: UK fund managers with AUM between £5 billion and £50 billion.
EU Deforestation Regulation applies to large and medium companies (deadline extended twice from 30 December 2024 and then December 2025)
In scope: Large and medium enterprises as defined in the Accounting Directive
Qualifying conditions:
Companies must assess whether they fall into scope of the Energy Savings Opportunity Regulations (Phase 4) which requires energy audits to be carried out. Large employers will be required to report on ethnicity and disability pay gaps, and also publish an equality action plan, setting out how they will reduce their gender pay gap and support employees through the menopause
In scope: Large undertakings (those meeting either the employee or both financial thresholds), and groups containing large undertakings.
Qualifying conditions:
2027
Large employers will be required to report on ethnicity and disability pay gaps. Large employers will also be required to produce an equality action plan setting out the steps they are taking to reduce their gender pay gap and how they support employees through the menopause.
In scope: Employers with 250 or more employees.
2027
Zero hours and minimum hours workers (including agency workers) will have a new right to be offered a regular hours contract if their working hours regularly exceed the zero/ minimum hour level over a set reference period. There will also be a right to reasonable notice of shifts and compensation if shifts are cancelled or curtailed
In scope: All organisations engaging workers on zero / minimum hour contracts or irregular hours workers.
Proposed introduction of mandatory reporting by listed companies in accordance with UK sustainability reporting standards based on ISSB standards, for financial years beginning on or after this date
In scope: Listed companies
Revised date for application of CSRD to large EU companies/groups; sustainability reporting in 2028 for FY beginning on or after 01-01-2027.
In scope: Large companies not previously covered by the Non-financial Reporting Directive (ie. any company which is not an SME under the Accounting Directive) In each case, satisfying at least two of the three size criteria
Qualifying condition: Turnover greater than or equal to EUR 50m, Number of employees greater than or equal to 1000.
EU Deforestation Regulation applies to micro and small companies – those meeting 2 of the 3 thresholds for turnover, balance sheet or employees (deadline extended from 30 June 2025)
In scope: Small and micro enterprises as defined in the Accounting Directive
Qualifying conditions:
Extended deadline for Commission to adopt limited assurance standards under the CSRD (previously 1 October 2026)
In scope: All entities in scope of the CSRD
Application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies. Omnibus proposes to delay this deadline by one year.
In scope:
"Group 1": Certain of the largest EU companies and groups;
"Group 2": Certain of the largest non-EU companies with turnover in the EU
Qualifying conditions:
Omnibus proposal would change the deadline for transposition by Member States and extend it by one year
In scope:
"Group 1": Certain of the largest EU companies and groups;
"Group 2": Certain of the largest non-EU companies with turnover in the EU
Qualifying condition:
Group 1: greater than EUR 450m net worldwide turnover
Group 2: greater than EUR 450m net turnover in the EU
Entities in scope of Phase 4 of ESOS must notify their compliance by this date
In scope: Large undertakings (those meeting either the employee or both financial thresholds), and groups containing large undertakings
Qualifying conditions:
Businesses placing or making available products on the EU market must ensure they are not made with forced labour. They must be able to demonstrate to competent authorities on request that they have taken appropriate steps to identify, prevent, mitigate or bring to an end the risk of forced labour in their operations and value chain, via due diligence.
In scope: Economic operators placing or making products available on the EU market
The 2023 update report to the Parker review recommends that FTSE 350 companies set a percentage target for senior management positions (for this purpose, members of the executive committee and senior managers who report directly to them) that will be occupied by ethnic minority executives in December 2027.
In scope: FTSE 350 companies
2028 (TBC)
otential date for the updated EU SFDR framework (known as SFDR 2.0) to begin to apply.
This is currently a legislative proposal and may therefore be subject to significant changes.
It is expected to introduce a replacement product categorisation framework which will specify new criteria for different categories of sustainable finance products and regulate permitted sustainability-related claims in marketing and investor disclosure and reporting communications relating to them.
The new categories will include Article 7 (Transition), Article 8 (ESG Basics) and Article 9 (Sustainable) products. There will also be updated criteria which will determine when a product does not fall within the categories of sustainability-related products (Article 6a).
In scope:
EU providers of financial products and non-EU financial product providers marketing products in the EU.
This includes fund managers, pension product providers and providers of insurance-based investment products.
Revised date of application of CSRD to listed SMEs; however, under the agreed Omnibus text, listed SMEs will no longer be in scope
In scope: Listed SMEs (except micro-enterprises)
Qualifying condition: Turnover greater than or equal to EUR 150m in the EU
Application of EU Corporate Sustainability Reporting Directive to non-EU companies; sustainability reporting in 2029 for FY beginning on or after 01-01-2028.
In scope: Non-EU companies with significant turnover in the EU and an EU subsidiary, or a branch with EUR200m turnover
Qualifying condition: Turnover greater than or equal to EUR 450m in the EU
Application date for the new UK regulated activity of providing an ESG rating.
Broadly, this will apply where a person provides an ESG rating (whether solicited or not) which is likely to influence an investment decision, and the person could reasonably have expected it to do so.
An ESG rating is an assessment regarding one or more ESG factors which is in the form of a score or opinion (or both) and is prepared using an established methodology and a defined ranking system.
Various exemptions apply.
In scope: Entities providing non-exempt ESG ratings
Application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies. Omnibus proposes to include the largest "wave 1" companies as of this date rather than one year earlier.
In scope:
"Group 1": Certain very large EU companies/ groups.
"Group 2": Certain very large non-EU companies/ groups
Qualifying conditions:
Omnibus Directive provided one extra year for transposition by Member States (already extended by one year by the Stop The Clock Directive)
In scope:
Group 1": Certain of the largest EU companies and groups;
"Group 2": Certain of the largest non-EU companies with turnover in the EU
"Group 3": certain EU and non-EU companies/groups who entered into large franchising or licensing agreements in the EU
Qualifying conditions:
Number of employees:
Application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies.
In scope:
"Group 1": Certain very large EU companies/ groups.
"Group 2": Certain very large non-EU companies/ groups
Qualifying conditions:
Companies in scope of the Corporate Sustainability Due Diligence Directive are required to publish their first annual due diligence statements for financial years beginning on or after 1 January 2030
In scope: All entities in scope of the CS3D
01 January 2030 (TBC)
Regulations expected to be introduced to provide that all rented non-domestic buildings must achieve EPC Band B, where cost-effective. This may involve introducing a performance-based rating scheme for large commercial and industrial buildings to provide investors and their tenants with more information on how to reduce energy consumption and lower both carbon emissions and energy bills.
In scope: All business organisations
Theme: Built environment
EU Commission's proposed revisions to the Energy Performance of Buildings Directive (EPBD) intend to require all new buildings to be zero-emission as of 2030.
In scope: All business organisations developing real estate in the EU
TBC
The UK Labour government included a commitment in its 2024 manifesto to mandate regulated UK financial institutions and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5° Paris Agreement goal.
Although it published a consultation in June 2025 setting out potential approaches, the proposals to implement this commitment have not yet been confirmed
In scope: UK regulated financial institutions, FTSE 100 companies
TBC
UK Government to amend the Environment Act to introduce due diligence requirements for larger businesses to prevent forests and natural areas from being converted illegally into agricultural land.
In scope: Larger businesses (based on turnover test to be confirmed) – subject to de minimis threshold for volume of commodity used
Theme: Climate change, environment and resources
Minimum Energy Efficiency Standard Regulations
In scope: All business organisations which own let residential units.
This ESG timeline is for general information purposes only and does not constitute legal or any other type of professional advice. Travers Smith does not accept and, to the extent permitted by law, excludes, liability to any person for any loss which may arise from relying upon, or otherwise using the information contained in, the timeline.
For more information on People issues please contact Adam Wyman.
For more information on Sustainable Finance issues, please contact Tim Lewis, Phil Bartram, Michael Raymond, Simon Witney, or Jonathan Gilmour.
For more information on Environment and Climate issues, please contact Sarah-Jane Denton or John Buttanshaw.
For more information on Tax issues, please contact Madeline Gowlett or Hannah Manning.
For more information on Pensions issues, please contact Susie Daykin.
For more information on Governance issues, please contact Aisling Arthur.
For more information on Real Estate issues, please contact Sarah Walker.
For more information on Competition issues, please contact Stephen Whitfield.
For more information on Litigation Risk issues, please contact Heather Gagen.
