Overview

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 July 2022. 

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Timeline by business type

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.

  • SFDR – periodic disclosure reporting requirements start to apply


    Disclosure Regulation (EU) 2019/2088 – key applicable dates for sustainability-related disclosures in the financial sector ("SFDR"): "Level 1" periodic disclosure reporting requirements begin to apply (but detailed RTS requirements postponed to 01/01/2023).

    In scope: Banks, investment firms, asset managers, insurers

    Theme: Sustainable finance and ESG reporting

  • EU Taxonomy Regulation reporting requirements on climate change mitigation and adaption to apply; additional reporting may apply for Arts 8 or 9 SFDR products


    EU Taxonomy Regulation – applicable date for the establishment of a framework to facilitate sustainable investment: EU Taxonomy Climate Delegated Act, the delegated act setting out technical screening criteria defining which activities contribute to climate change mitigation and adaptation to apply. Additional reporting requirements may also apply for Art 8 or 9 SFDR products.

    In scope: Financial markets participants, issuers of financial products and large public interest entities

    Theme: Climate change, environment and resources &

    Sustainable finance and ESG reporting

  • EU Taxonomy Regulation – Delegated Regulation specifying content and presentation of Article 8 disclosures to apply


    EU Taxonomy Regulation – applicable date for the Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 (non-financial statements).

    In scope: Certain large public interest entities meeting relevant size criteria

    Qualifying conditions:

    • Turnover greater than or equal to EUR40m
    • Balance sheet or assets greater than or equal to EUR20m
    • Number of employees greater than or equal to 500

    Theme: Climate change, environment and resources

    Sustainable finance and ESG reporting

  • UK TCFD disclosure requirements in force for largest asset managers and asset owners


    UK TCFD (FCA ESG rules) – largest UK-authorised asset managers and asset owners to make climate-related financial disclosures consistent with TCFD Recommendations and Recommended Disclosures. Publication deadline for first public disclosures 30/06/2023.

    In scope: Largest UK-authorised asset managers and asset owners

    Qualifying condition: Asset managers with AuM ≥£50bn. Asset owners with in-scope assets of £25bn or more

    Theme: Sustainable finance and ESG reporting

  • TCFD disclosure requirements for standard listed companies


    TCFD  – climate-related disclosure requirements apply to (i) issuers of standard listed shares other than equity shares and (ii) standard listed issuers of GDRs (in each case excluding investment entities and shell companies such as SPACs) for financial years beginning on or after 1 January 2022.

    In scope: Standard listed companies

    Theme: Sustainable finance and ESG reporting

  • EU update on list of non-cooperative jurisdictions for tax purposes published

    February 2022

    EU update on list of non-cooperative jurisdictions for tax purposes published.  EU member states have introduced "defensive measures" which have adverse consequences for jurisdictions on the list. The list is updated twice a year.

    In scope: Entities in or affected by countries on the EU list of non-cooperative jurisdictions for tax purposes

    Theme: Tax

  • FTSE Women Leaders Review

    February 2022

    Publication of the FTSE Women Leaders Review: an independent business-led framework supported by the Government, to build on the Hampton-Alexander Review. Will monitor women's representation in senior leadership positions in FTSE 350 companies in the next 5 years.

    In scope: FTSE 350 companies

    Theme: People

  • Publication of draft Directive on corporate sustainability due diligence


    Publication of draft Directive on corporate sustainability due diligence (see our briefing)

    In scope:

    • Entities based in the EU meeting turnover and employee thresholds
    • Non-EU entities with significant turnover in the EU

    Qualifying conditions:

    • Turnover > EUR 150m (EUR 40m in high-risk sectors)
    • Number of employees ≥500 (≥250 in high-risk sectors) (N/A to non-EU entities)

     

    Theme: Sustainable finance and ESG reporting

  • BEIS guidance on TCFD disclosures available


    BIES published non-binding guidance on the requirement for larger private and public companies to make TCFD disclosures (see below). See our briefing note for more detail.

    In scope: Listed companies and larger AIM-listed or private companies and LLPs

    Qualifying conditions:

    • ≥£500m*

      *application of thresholds varies depending on entity type. See our briefing for more detail
    • Number of employees ≥500*
      *application of thresholds varies depending on entity type. See our briefing for more detail.

    Theme: Sustainable finance and ESG reporting

  • Appendix added to Pensions Regulator guidance on governance and reporting of climate-related risks and opportunities for in-scope occupational pension schemes

    March 2022

    The Pensions Regulator added an appendix to its guidance for trustees of in-scope occupational pension schemes on the governance and reporting of climate-related risks and opportunities.

    In scope: In-scope pension scheme trustees

    Theme: Sustainable finance and ESG reporting

  • New Listing Rules requirement re. board and senior management diversity targets

    1 April 2022 (applies to financial years beginning on or after this date)

    New requirement in Listing Rules for issuers to (1) publish an annual "comply or explain statement" in relation to prescribed board diversity targets; and (2) include numerical data on the sex or gender identity and ethnic diversity of a company's board and senior management.

    In scope: Premium and standard listed UK and overseas companies, including closed-ended investment funds.

    Theme: People

  • New disclosure requirement in DTRs re. diversity on board committees

    1 April 2022 (applies to financial years beginning on or after this date)

    New requirement in DTRs to disclose how the company’s diversity policy has applied to its remuneration, audit and nominations committees, having regard to diversity aspects such as ethnicity, sexual orientation, disability and socio-economic background.

    In scope: UK listed issuers 

    Theme: People

  • TCFD disclosures required of listed companies and large private and public companies and LLPs


    TCFD – listed companies, larger private and public companies, and LLPs required to make disclosures aligned with TCFD (Taskforce on Climate-Related Financial Disclosures) recommendations.  See our briefing note for more detail.

    In scope: Larger non-premium listed companies, AIM-listed companies, larger private companies and LLPs

    Qualifying conditions: 

    • Turnover ≥£500m*
      *application of thresholds varies depending on entity type. See our briefing for more detail.
    • Number of employees ≥500*
      *application of thresholds varies depending on entity type. See our briefing for more detail.

    Theme: Sustainable finance and ESG reporting

  • Tax returns filed after April 2022 may require disclosure of uncertain tax treatment

    April 2022

    Tax returns filed by large business organisations after this date are required to take into account a new requirement to notify HMRC where the business has adopted an uncertain tax treatment. 

    In scope: Businesses whose UK turnover and/or balance sheet exceeds certain financial thresholds. There are some exceptions, e.g. collective investment schemes

    Qualifying conditions:

    • Turnover greater than or equal to £200m
    • Balance sheet or assets greater than or equal to £2bn 

    Theme: Tax

  • EU AIFMs and EU UCITS managers to integrate sustainability risks and factors


    EU AIFMD/EU UCITS – sustainability risks and sustainability factors to be taken into account as part of operating conditions.

    In scope: EU AIFMs; EU UCITS

    Theme: ESG

  • Deadline for transposition of Transparent and Predictable Working Conditions Directive by EU Member States

    01 August 2022

    The Transparent and Predictable Working Conditions Directive is aimed at improving conditions for casual/zero hours workers - including compensation if an assignment is cancelled without reasonable notice, and a right to request more predictable working conditions after six months.

    In scope: All business organisations

    Theme: People

  • Integration of sustainability into EU MiFID organisational requirements and operating conditions


    EU MiFID II – certain investment firms to integrate sustainability factors, risks and preferences into organisational requirements and operating conditions.

    In scope: Investment firms (financial advisers and portfolio managers)

    Theme: Sustainable finance and ESG reporting

  • Deadline for comment on draft standards under EU Corporate Sustainability Reporting Directive


    Deadline for comment on EFRAG exposure draft standards implementing the (draft) EU 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

    Sustainable finance and ESG reporting

  • New requirement for pension scheme trustees to calculate and report alignment with Paris Agreement


    Regulations require trustees of occupational pension schemes with £1bn+ in assets to calculate and disclose an additional portfolio alignment metric, setting out the extent to which scheme investments are aligned with the Paris Agreement goal of limiting global temperature increase to 1.5° above pre-industrial levels.

    In scope: Pension scheme trustees

    Qualifying condition: Pension scheme assets ≥£1bn

    Theme: Sustainable finance and ESG reporting

  • TCFD disclosures required of >£1bn pension schemes


    TCFD - Trustees of occupational pension schemes with £1billion+ in assets required under Pension Schemes Act 2021 regulations to comply with enhanced climate governance requirements from October 2022, with the first TCFD-aligned public disclosures to be made within seven months of scheme year end. (Schemes with £5bn+ in assets were subject to the requirements a year earlier.)

    In scope: Pension scheme trustees

    Qualifying condition: >£1bn pension scheme assets

    Theme: Sustainable finance and ESG reporting

  • UK Sustainability Regime: FCA proposals for Sustainability Disclosure Requirements and investment labels

    25 October 2022

    FCA published a consultation paper (CP22/20) on Sustainability Disclosure Requirements (SDR) and investment labels

    FCA sets out proposals relating to sustainable investment product labels (three labels are proposed – sustainable focus, sustainable improvers and sustainable impact), naming and marketing rules (including a general 'anti-greenwashing' rule) and a Sustainable Disclosure Requirements regime (SDR): consumer facing product-level disclosures, pre-contractual disclosures, ongoing sustainability-related performance information, entity-level disclosures and detailed disclosure requirements for distributors of products.

    The FCA intends the final rules to be effective 30 June 2023 – an 'anti-greenwashing' rule applicable to all firms will apply then, with the sustainable investment labels regime and the various elements of SDR to apply on a phased basis from 30 June 2024. See our briefing for further details.

    In scope: All regulated firms (as regards 'anti-greenwashing' rule), otherwise UK asset managers; "portfolio managers" (extends to capture private equity and other private market advisory activities).

    Theme: Sustainable finance and ESG reporting

  • COP27 took place in Sharm El-Sheikh, Egypt

    6-18 November 2022

    Sharm El Sheikh, Egypt hosts 27th UN Climate Change Conference of the Parties (COP27)

    In scope: All business organisations

    Theme: Climate change, environment and resources

  • Sustainability factors to be integrated into EU MiFID II product governance


    22 November 2022

    EU MiFID II – sustainability factors to be integrated into MiFID II product governance obligations.

    In scope: Investment firms

    Theme: Sustainable finance and ESG reporting

  • Ban on exclusivity clauses for lower paid workers in force

    5 December 2022

    The UK Government has introduced a ban on exclusivity clauses in employment contracts for lower paid workers (anyone earning below the lower earnings limit, currently £123 per week). An exclusivity clause is any clause which prevents the worker from working elsewhere (or requires the employer's consent to do so). Such clauses are prohibited in contracts for zero hours workers and, since 5 December 2022, are also unenforceable in contracts for lower paid workers.

    In scope: All business organisations

    Theme: People

  • Government sets targets under Environment Act

    16 December 2022

    UK Government published new targets under the Environment Act, including in respect of biodiversity, waste and air quality.

    In scope: All business organisations

    Theme: Climate change, environment and resources

  • Adoption of Kunming-Montreal Global Biodiversity Framework

    19 December 2022

    Adoption of global biodiversity agreement at COP15.

    In scope: All business organisations

    Theme: Climate change, environment and resources

  • ESG disclosure requirements under EU Investment Firms Regulation to apply


    ESG disclosure requirements under EU Investment Firms Regulation to apply

    In scope: Larger investment firms

    Theme: Sustainable finance and ESG reporting

  • SFDR - Additional reporting requirements may apply (adverse sustainability impacts disclosed at a financial 'product' level)


    Disclosure Regulation (EU) 2019/2088 – key applicable dates for sustainability-related disclosures in the financial sector ("SFDR"): Additional reporting requirements may apply (adverse sustainability impacts disclosed at a financial 'product' level)

    In scope: Banks, investment firms, asset managers, insurers

    Theme: Sustainable finance and ESG reporting

  • UK proposals for decarbonising Combined Heat and Power plant expected

    Late 2022 (see note on timing)

    Details expected of UK Government proposals to help incentivise transition away from fossil fuel Combined Heat and Power (CHP) plant, potentially including financial incentives.

    NOTE: these were expected in late 2022 but no news as at Jan 2023.

    In scope: All business organisations operating in the UK

    Theme: Climate change, environment and resources

  • Single Code of Practice for occupational pension schemes

    Early 2023

    Pensions Regulator expected to lay a Single Code of Practice before Parliament; expected to include 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

    Theme: Sustainable finance and ESG reporting

  • EU Taxonomy Regulation - reporting requirements on four remaining environmental objectives to apply; additional reporting may apply for Arts 8 or 9 SFDR products


    EU Taxonomy Regulation – delegated acts on four remaining environmental objectives (Water and Marine Resources, Circular Economy, Pollution Prevention and Biodiversity and Ecosystems) to apply. Additional reporting requirements may apply for Art 8 or 9 SFDR products in relation to those objectives.

    In scope: Financial markets participants, issuers of financial products and large public interest entities meeting relevant size criteria

    Qualifying conditions for large public interest entities:

    • Turnover greater than or equal to EUR40m
    • Balance sheet or assets greater than or equal to EUR20m
    • Number of employees greater than or equal to 500

    Theme: Climate change, environment and resources &

    Sustainable finance and ESG reporting

  • EU Taxonomy Regulation – Delegated Regulation specifying content and presentation of Article 8 – additional disclosures to apply


    EU Taxonomy Regulation: Additional requirements under Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 (non-financial statements) apply.

    In scope: Large non-financial public interest entities

    Theme: Climate change, environment and resources & Sustainable finance and ESG reporting

  • EU Taxonomy Regulation – inclusion of nuclear and natural gas in Taxonomy


    EU Taxonomy Regulation – application of the proposed Complementary Climate Delegated Act, amending the EU Taxonomy Climate Delegated Act and setting out the conditions under which nuclear and natural gas can be included.

    In scope: Banks, investment firms, asset managers, insurers

    Theme: Climate change, environment and resources &

    Sustainable finance and ESG reporting

  • SFDR – Regulatory Technical Standards to apply


    Disclosure Regulation (EU) 2019/2088 –sustainability-related disclosures in the financial sector ("SFDR"): Regulatory Technical Standards supplementing the SFDR requirements due to apply.

    In scope: Banks, investment firms, asset managers, insurers

    Theme: Sustainable finance and ESG reporting

  • Additional UK TCFD disclosure requirements in force for asset managers and owners, life and personal pension providers


    UK TCFD (FCA ESG rules) – UK-authorised asset managers and asset owners, life insurers and FCA-regulated pension providers 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. Publication deadline for first public disclosures 30/06/2024.

    In scope:  UK-authorised asset managers and asset owners

    Qualifying condition: In-scope assets ≥£5bn (asset managers) or between £5bn and £25bn (asset owners)

    Theme: Sustainable finance and ESG reporting

  • CSRD enters into force


    Directive (EU) 2022/2464 on Corporate Sustainability Reporting in force.

    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.


    Theme: Sustainable finance and ESG reporting

  • End of transition period for implementation of the Register of Overseas Entities


    The Register of Overseas Entities came into force on 1 August 2022.  Before the end of the transition period on 31 January 2023, overseas entities that want to buy, sell or transfer qualifying property in the UK must register with Companies House and tell them who their registrable beneficial owners or managing officers are.  Overseas entities that acquired qualifying property on or after 1 January 1999 in England and Wales, or 8 December 2014 in Scotland, must notify Companies House about this.  Failure to register on time may lead to prosecution or civil financial penalties.  Overseas entities that fail to register will also find it difficult to sell, lease or raise charges over their land.

    In scope:

    • All overseas entities holding, disposing of, charging or acquiring UK real estate; UK registered real estate owners contracting with an overseas entity.

    Theme: Built environment

  • Implementing MDR in the UK


    Regulations to come into force implementing in the UK the OECD's Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (MDR).  These regulations will replace the UK's similar DAC 6 rules currently in force. The Government has indicated that the MDR regulations will come into force "in the first half of 2023".

    In scope: All business organisations

    Theme: Tax

  • New Modern Slavery Bill expected


    A new Modern Slavery Bill (proposing amendments to the Modern Slavery Act 2015) was announced in June 2022. Expected to be published in early 2023, the Bill is likely to introduce additional criminal offences designed to encourage businesses to address problem suppliers and make more accurate and complete statements.

    In scope:

    • All business organisations of a certain size operating in the UK


    Qualifying condition: Turnover greater than or equal to: £36m

    Theme: People

  • MEES Regulations Prohibition on letting properties with an EPC rating of F or less


    For commercial properties there will be a prohibition on continuing to let properties with an EPC rating of "F" or less. Whilst there is no express obligation to bring relevant properties up to a compliant standard under the MEES Regulations, local authorities will have enforcement powers, including the ability to impose penalties.

    In scope: All business organisations

    Theme: Built Environment

  • Expected adoption of reporting standards under EU CSRD

    June 2023

    Expected date of adoption of delegated acts adopting cross-sector reporting standards under the 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

    Theme: Sustainable finance and ESG reporting

  • Expected publication of Sustainability Disclosure Requirements to apply to companies, financial institutions and occupational pension schemes. Effective date TBC

    June 2023

    Expected date for the FCA to publish its final rules on sustainability disclosure requirements (SDR) and investment labels. Current proposals suggest these will include requirements relating to sustainable investment product labels (three labels are proposed - sustainable focus, sustainable improvers and sustainable impact), naming and marketing rules (including a general ‘anti-greenwashing’ rule), consumer-facing product-level disclosures and detailed disclosures requirements for distributors of products.

    In scope: 

    • All UK-regulated investment firms and asset managers;

    • Occupational pension schemes (scope tbc).

    Theme: Sustainable finance and ESG reporting

  • Expected consultation on Future Buildings Standard

    1 June 2023

    Expected date of further consultation on the detailed technical aspects of the UK Government's Future Buildings Standard which will set out more stringent efficiency standards, to ensure that new buildings are 'zero carbon ready' from 2025.

    In scope: All real estate developers in the UK

    Theme: Built environment

  • Deadline for FCA ESG disclosures for largest asset managers and owners

    30 June 2023

    Deadline for UK-authorised asset managers with in-scope assets ≥£50bn and asset owners with in-scope assets ≥£25bn to make climate-related financial disclosures consistent with TCFD Recommendations.

    In scope: Largest UK-authorised asset managers and asset owners

    Qualifying conditions: In-scope assets ≥£50bn (asset managers) or ≥£25bn (asset owners)

    Theme: Sustainable finance and ESG reporting

  • First principal adverse impacts statement under SFDR regulatory technical standards

    30 June 2023

    First principal adverse impacts statement under SFDR regulatory technical standards.

    In scope:

    • Banks,
    • investment firms,
    • asset managers,
    • insurers


    Theme: Sustainable finance and ESG reporting

  • UK Sustainability Disclosure Regime (SDR) and investment labels – final rules

    Mid-2023

    FCA intends its final rules on a new regime for Sustainability Disclosure Requirements (SDR) and investment labelling to start coming into force on a phased basis, starting with a general 'anti-greenwashing' rule applicable to all firms which will be effective on 30/06/2023. Requirements applicable to sustainable investment labels, consumer-facing disclosures, pre-contractual disclosures, naming and marketing rules, ongoing sustainability-related performance information, entity-level disclosures and distributors are expected to become effective on specified dates between 30/06/2024 and 30/06/2026.

    In scope:

    • All regulated firms (as regards 'anti-greenwashing' rule), otherwise UK asset managers; "portfolio managers" (extends to capture private equity and other private market advisory activities).


    Theme: Sustainable finance and ESG reporting

  • Revised text of EU's Pay Transparency Directive expected

    Summer 2023

    It is currently expected that the EU's Pay Transparency Directive will oblige all companies to provide certain information to jobseekers/employees; and larger companies (current proposals are 250+ employees, but lowering this to 50 is being discussed) to publicly report on gender pay gap. Recent negotiations suggest a gender action plan where pay gap is higher than 2.5% may also be required.

    In scope: Larger businesses

    Qualifying conditions: number of employees greater than or equal to: 50

    Theme: People

  • UK Biodiversity Net Gain requirement applies to new developments in UK


    The UK's Environment Act 2021 will require all new real estate developments to deliver a 10% 'biodiversity net gain' from November 2023, which will effectively become a requirement of its planning permission. This can be delivered through on-site or off-site measures or a combination.

    In scope: All businesses developing real estate in the UK

    Theme: Built environment

  • Deadline for Energy Efficiency Directive "Article 8" audit

    Late-2023

    The EU Energy Efficiency Directive requires businesses to periodically audit their energy use and identify (and cost) potential energy savings. The deadline for audits varies across EU member states, but in most cases falls in late 2023.

    Qualifying conditions: Turnover: ≥£50m, Balance sheet or assets: ≥£43m, Employees: ≥250

    In scope: All business organisations of a certain size operating in the EU

    Theme: Climate change, environment and resources

  • Deadline for Energy Savings Opportunity Scheme (ESOS) Audit


    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. Note that amendments expanding the scope of the UK regime are expected to take effect prior to this date, in early 2023. Scope of the audit may need careful consideration in context of any applicable franchise/management arrangements.

    Qualifying conditions: Turnover: £50m, Balance sheet or assets: £43m, Employees: 250

    In scope: All business organisations of a certain size operating in the UK

    Theme: Climate change, environment and resources

  • EU Whistleblowing Directive to apply to small/medium private sector entities


    EU Whistleblowing Directive: national implementing legislation to apply to small/medium private sector entities operating in the EU, requiring them to have a whistleblowing policy.

    In scope: All business organisations of a certain size operating in the EU

    Qualifying conditions:

    • Number of employees 50-249

    Theme: People

  • Target date for global implementation of the OECD's BEPS Pillar One rules. The rules will reallocate 25% of the profits in excess of 10% of revenue of a multinational enterprise (MNE) to market jurisdictions where the MNE has a substantial engagement in that market, regardless of whether it has a physical presence there.


    End of 2023

    Extremely large MNEs. There are to be exclusions for extractives and regulated financial services

    In scope: Global turnover  >€20bn (reducing to €10bn in no earlier than seven years) and profitability >10%

    Theme: Tax

  • Target date for global implementation of BEPS Pillar One rules


    End of 2023

    Target date for global implementation of the OECD's BEPS Pillar One rules. The rules will reallocate 25% of the profits in excess of 10% of revenue of a multinational enterprise (MNE) to market jurisdictions where the MNE has a substantial engagement in that market, regardless of whether it has a physical presence there.

    In scope: Extremely large MNEs. There are to be exclusions for extractives and regulated financial services

    Qualifying condition: Global turnover above €20bn (reducing to €10bn in no earlier than seven years) and profitability above 10%

    Theme: Tax

  • Target date for global implementation of most of the BEPS Pillar Two rules

    2023 (but some rules to come into effect in 2024)

    Target date for global implementation of most of the OECD's BEPS Pillar Two rules. The main plank of Pillar Two is the Global anti-Base Erosion rules (GloBE rules) which seek to establish a global minimum corporate tax rate of 15% for multinational enterprises (MNEs). The UK and EU are not expected to implement any aspects of Pillar Two before 31 December 2022.

    In scope: Large MNEs. There are to be various exclusions, including for investment funds that are ultimate parent entities of an MNE group and pension funds (and any holding vehicles used by such funds).

    Theme: Tax

  • EU Taxonomy Regulation – Delegated Regulation specifying content and presentation of Article 8 - additional disclosures to apply


    EU Taxonomy Regulation – Additional requirements under Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 to apply.

    In scope: Large financial public interest entities

    Theme: Climate change, environment and resources

  • Start of first reporting period under CSRD for PIEs


    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

  • Expected publication of first sector-specific reporting standards for high-risk sectors under CSRD


    Expected date of publication of first sector-specific reporting standards under the 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.


    Theme: Sustainable finance and ESG reporting

  • Additional deadline for FCA ESG disclosures for asset managers and owners


    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

    Qualifying conditions: In-scope assets ≥£5bn (asset managers) or between £5bn and £25bn (asset owners)

    Theme: Sustainable finance and ESG reporting

  • Possible application of new regulatory framework for Heat Networks


    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

    Qualifying conditions: In-scope assets ≥£5bn (asset managers) or between £5bn and £25bn (asset owners)

    Theme: Built environment

  • Parker ethnic diversity target for FTSE 250 in force


    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 on each FTSE 250 board by 2024.

    In scope: Listed companies – FTSE 250

    Theme: People

  • Possible application of EU Corporate Sustainability Due Diligence Directive to certain EU and non-EU companies

    2024 (TBC)

    Possible application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies

    In scope:

    • "Group 1": Large EU companies and non-EU companies active in the EU;
    • "Group 2": EU "high impact" companies and non-EU "high impact" companies active in the EU [*Note: Group 2 excludes financial sector]


    Qualifying conditions:

    • Employees: >500, >250 (EU only)


    Theme: Sustainable finance and ESG reporting

  • TCFD governance and (later) disclosures may be required of smaller pension schemes


    Smaller occupational pension schemes may become subject to TCFD governance and disclosure requirements. This is subject to a review in late 2023 and a consultation in 2024.

    Qualifying conditions: Balance sheets or assets greater than or equal to - TBC

    In scope: Pension scheme trustees (subject to review)

    Theme: Sustainable finance and ESG reporting

  • Start of first reporting period under CSRD for large EU companies


    Application of CSRD  to large EU companies; sustainability reporting in 2026 for FY beginning on or after 01-01-2025

    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:

    • Turnover of EUR 40m
    • Balance sheet of EUR20m
    • 250 employees


    Theme: Sustainable finance and ESG reporting

  • UK's Future Buildings Standard implemented


    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

  • Start of first reporting period under CSRD for listed SMEs


    Application of CSRD  to listed SMEs; sustainability reporting in 2027 for FY beginning on or after 01-01-2026.

    In scope: Listed SMEs (except micro-enterprises)

    Theme: Sustainable finance and ESG reporting

  • Energy Performance Certificates to be harmonised across EU


    Energy Performance Certificates to be harmonised across the EU, and trigger to obtain a certificate to be extended to include major renovations (in addition to sales and leases).

    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

  • EU board gender diversity requirements apply


    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: Turnover greater than or equal to EUR 50m. Balance sheet or assets greater than or equal to EUR 43m. Greater or equal to 250 employees

    Theme: People

  • Application of CSRD to non-EU companies


    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

    Qualifying condition: Turnover greater than or equal to EUR 150m in the EU

  • All rented non-domestic buildings must achieve EPC Band B, where cost-effective


    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

  • Energy Performance of Buildings Directive to require new [buildings] to be zero emission

    01 January 2030

    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

    Theme: Built environment

  • New duty to prevent workplace sexual harassment

    TBC

    UK Government to introduce a positive duty on employers to prevent workplace sexual harassment, including harassment of staff by third parties. No date has been set.

    In scope: All businesses 

    Theme: People

  • UK Government to introduce due diligence requirements to prevent forests and natural areas from being converted illegally into agricultural land

    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 

Timeline by ESG theme
  • SFDR – periodic disclosure reporting requirements start to apply


    Disclosure Regulation (EU) 2019/2088 – key applicable dates for sustainability-related disclosures in the financial sector ("SFDR"): "Level 1" periodic disclosure reporting requirements begin to apply (but detailed RTS requirements postponed to 01/01/2023).

    In scope: Banks, investment firms, asset managers, insurers

  • EU Taxonomy Regulation reporting requirements on climate change mitigation and adaption to apply; additional reporting may apply for Arts 8 or 9 SFDR products


    EU Taxonomy Regulation – applicable date for the establishment of a framework to facilitate sustainable investment: EU Taxonomy Climate Delegated Act, the delegated acts setting out technical screening criteria defining which activities contribute to climate change mitigation and adaptation to apply. Additional reporting requirements may also apply for Art 8 or 9 SFDR products.

    In scope: Financial markets participants, issuers of financial products and large public interest entities

  • EU Taxonomy Regulation – Delegated Regulation specifying content and presentation of Article 8 disclosures to apply


    EU Taxonomy Regulation – applicable date for the Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 (non-financial statements).

    In scope: Certain large public interest entities meeting relevant size criteria

    Qualifying conditions:

    • Turnover greater than or equal to EUR40m
    • Balance sheet or assets greater than or equal to EUR20m
    • Number of employees greater than or equal to 500
  • UK TCFD disclosure requirements in force for largest asset managers and asset owners


    UK TCFD (FCA ESG rules) – largest UK-authorised asset managers and asset owners to make climate-related financial disclosures consistent with TCFD Recommendations and Recommended Disclosures. Publication deadline for first public disclosures 30/06/2023.

    In scope: Largest UK-authorised asset managers and asset owners

    Qualifying condition: Asset managers with AuM >£50bn; Asset owners with in-scope assets of £25bn or more

  • TCFD disclosure requirements for standard listed companies


    TCFD  – climate-related disclosure requirements apply to (i) issuers of standard listed shares other than equity shares and (ii) standard listed issuers of GDRs (in each case excluding investment entities and shell companies such as SPACs) for financial years beginning on or after 1 January 2022.

    In scope: Standard listed companies

  • EU update on list of non-cooperative jurisdictions for tax purposes published

    February 2022

    EU update on list of non-cooperative jurisdictions for tax purposes published.  EU member states have introduced "defensive measures" which have adverse consequences for jurisdictions on the list. The list is updated twice a year.

    In scope: Entities in or affected by countries on the EU list of non-cooperative jurisdictions for tax purposes.

  • FTSE Women Leaders Review

    February 2022

    Publication of the FTSE Women Leaders Review: an independent business-led framework supported by the Government, to build on the Hampton-Alexander Review. Will monitor women's representation in senior leadership positions in FSTSE 350 companies in the next 5 years.

    In scope: FTSE 350 companies

  • Publication of draft Directive on corporate sustainability due diligence


    Publication of draft Directive on corporate sustainability due diligence (see our briefing)

    In scope:

    • Entities based in the EU meeting turnover and employee thresholds [Non-EU entities with significant turnover in the EU

    Qualifying conditions:

    • Turnover greater than or equal to EUR 150m (EUR 40m in high-risk sectors)
    • Number of employees greater than 500 (or greater than 250 in high-risk sectors) (N/A to non-EU entities)
  • BEIS guidance on TCFD disclosures available


    BIES published non-binding guidance on the requirement for larger private and public companies to make TCFD disclosures (see below). See our briefing note for more detail.

    In scope: Listed companies and larger AIM-listed or private companies and LLPs

    Qualifying conditions:

    • Turnover > £500m*
      *application of thresholds varies depending on entity type. See our briefing for more detail.
    • Number of employees less than 500*
      *application of thresholds varies depending on entity type. See our briefing for more detail.
  • Appendix added to Pensions Regulator guidance on governance and reporting of climate-related risks and opportunities for in-scope occupational pension schemes

    March 2022

    The Pensions Regulator added an appendix to its guidance for trustees of in-scope occupational pension schemes on the governance and reporting of climate-related risks and opportunities.

    In scope: In-scope pension scheme trustees

  • New Listing Rules requirement re. board and senior management diversity targets

    1 April 2022 (applies to financial years beginning on or after this date)

    New requirement in Listing Rules for issuers to (1) publish an annual "comply or explain statement" in relation to prescribed board diversity targets; and (2) include numerical data on the sex or gender identity and ethnic diversity of a company's board and senior management.

    In scope: Premium and standard listed UK and overseas companies, including closed-ended investment funds.

  • New disclosure requirement in DTRs re. diversity on board committees

    1 April 2022 (applies to financial years beginning on or after this date)

    New requirement in DTRs to disclose how the company’s diversity policy has applied to its remuneration, audit and nominations committees, having regard to diversity aspects such as ethnicity, sexual orientation, disability and socio-economic background.

    In scope: UK listed issuers 

  • TCFD disclosures required of listed companies and large private and public companies and LLPs


    TCFD – listed companies, larger private and public companies, and LLPs required to make disclosures aligned with TCFD (Taskforce on Climate-Related Financial Disclosures) recommendations.  See our briefing note for more detail.

    In scope: Larger non-premium listed companies, AIM-listed companies, larger private companies and LLPs

    Qualifying conditions: 

    • Turnover > £500m*
      *application of thresholds varies depending on entity type. See our briefing for more detail.
    • Number of employees > 500*
      *application of thresholds varies depending on entity type. See our briefing for more detail.
  • Tax returns filed after April 2022 may require disclosure of uncertain tax treatment

    April 2022

    Tax returns filed by large business organisations after this date are required to take into account a new requirement to notify HMRC where the business has adopted an uncertain tax treatment. 

    In scope: Businesses whose UK turnover and/or balance sheet exceeds certain financial thresholds. There are some exceptions, e.g. collective investment schemes

    Qualifying conditions:

    • Turnover greater than or equal to £200m
    • Balance sheet or assets greater than or equal to £2bn
  • EU AIFMs and EU UCITS managers to integrate sustainability risks and factors


    EU AIFMD/EU UCITS – sustainability risks and sustainability factors to be taken into account as part of operating conditions.

    In scope: EU AIFMs; EU UCITS

  • Deadline for transposition of Transparent and Predictable Working Conditions Directive by EU Member States


    The Transparent and Predictable Working Conditions Directive is aimed at improving conditions for casual/zero hours workers - including compensation if an assignment is cancelled without reasonable notice, and a right to request more predictable working conditions after six months.

    In scope: All business organisations

  • Integration of sustainability into EU MiFID organisational requirements and operating conditions


    EU MiFID II – certain investment firms to integrate sustainability factors, risks and preferences into organisational requirements and operating conditions.

    In scope: Investment firms (financial advisers and portfolio managers)

  • Deadline for comment on draft standards under EU Corporate Sustainability Reporting Directive


    Deadline for comment on EFRAG exposure draft standards implementing the (draft) EU 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
  • New requirement for pension scheme trustees to calculate and report alignment with Paris Agreement


    Regulations require trustees of  occupational pension schemes with £1bn+ in assets to calculate and disclose an additional portfolio alignment metric, setting out the extent to which scheme investments are aligned with the Paris Agreement goal of limiting global temperature increase to 1.5° above pre-industrial levels.

    In scope: Pension scheme trustees

    Qualifying condition: Balance sheet or assets greater than or equal to Pension scheme assets >£1bn

  • TCFD disclosures required of >£1bn pension schemes


    TCFD - Trustees of occupational pension schemes with £1billion+ in assets required under Pension Schemes Act 2021 regulations to comply with enhanced climate governance requirements from October 2022, with the first TCFD-aligned public disclosures to be made within seven months of scheme year end. (Schemes with £5bn+ in assets were subject to the requirements a year earlier.)

    In scope: Pension scheme trustees

    Qualifying condition: Balance sheet or assets greater than or equal to >£1bn pension scheme assets

  • UK Sustainability Regime: FCA proposals for Sustainability Disclosure Requirements and investment labels


    FCA published a consultation paper (CP22/20) on Sustainability Disclosure Requirements (SDR) and investment labels 

    FCA sets out proposals relating to sustainable investment product labels (three labels are proposed – sustainable focus, sustainable improvers and sustainable impact), naming and marketing rules (including a general 'anti-greenwashing' rule) and a Sustainable Disclosure Requirements regime (SDR): consumer facing product-level disclosures, pre-contractual disclosures, ongoing sustainability-related performance information, entity-level disclosures and detailed disclosure requirements for distributors of products.

    The FCA intends the final rules to be effective 30 June 2023 – an 'anti-greenwashing' rule applicable to all firms will apply then, with the sustainable investment labels regime and the various elements of SDR to apply on a phased basis from 30 June 2024. See our briefing for further details.

    In scope: All regulated firms (as regards 'anti-greenwashing' rule), otherwise UK asset managers; "portfolio managers" (extends to capture private equity and other private market advisory activities).

  • COP27 took place in Sharm El-Sheikh, Egypt


    Sharm El Sheikh, Egypt hosts 27th UN Climate Change Conference of the Parties (COP27)

    In scope: All business organisations

  • Sustainability factors to be integrated into EU MiFID II product governance


    EU MiFID II – sustainability factors to be integrated into MiFID II product governance obligations.

    In scope: Investment firms 

  • Ban on exclusivity clauses for lower paid workers in force


    The UK Government has introduced a ban on exclusivity clauses in employment contracts for lower paid workers (anyone earning below the lower earnings limit, currently £123 per week). An exclusivity clause is any clause which prevents the worker from working elsewhere (or requires the employer's consent to do so). Such clauses are prohibited in contracts for zero hours workers and, since 5 December 2022, are also unenforceable in contracts for lower paid workers.

    In scope: All business organisations

  • Government sets targets under Environment Act


    UK Government published new targets under the Environment Act, including in respect of biodiversity, waste and air quality.

    In scope: All business organisations

  • Adoption of Kunming-Montreal Global Biodiversity Framework


    Adoption of global biodiversity agreement at COP15.

    In scope: All business organisations

  • ESG disclosure requirements under EU Investment Firms Regulation to apply


    ESG disclosure requirements under EU Investment Firms Regulation to apply

    In scope: Larger investment firms

  • SFDR - Additional reporting requirements may apply (adverse sustainability impacts disclosed at a financial 'product' level)


    Disclosure Regulation (EU) 2019/2088 – key applicable dates for sustainability-related disclosures in the financial sector ("SFDR"): Additional reporting requirements may apply (adverse sustainability impacts disclosed at a financial 'product' level).

    In scope: Banks, investment firms, asset managers, insurers

  • UK proposals for decarbonising Combined Heat and Power plant expected


    Details expected of UK Government proposals to help incentivise transition away from fossil fuel Combined Heat and Power (CHP) plant, potentially including financial incentives.

    NOTE: these were expected in late 2022 but no news as at Jan 2023.

    In scope: All business organisations operating in the UK

  • Single Code of Practice for occupational pension schemes


    Early 2023

    Pensions Regulator expected to lay a Single Code of Practice before Parliament; expected to include 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

  • EU Taxonomy Regulation - reporting requirements on four remaining environmental objectives to apply; additional reporting may apply for Arts 8 or 9 SFDR products


    EU Taxonomy Regulation – delegated acts on four remaining environmental objectives (Water and Marine Resources, Circular Economy, Pollution Prevention and Biodiversity and Ecosystems) to apply. Additional reporting requirements may apply for Art 8 or 9 SFDR products in relation to those objectives.

    Qualifying conditions for large public interest entities:

    • Turnover greater than or equal to EUR40m
    • Balance sheet or assets greater than or equal to EUR20m
    • Number of employees greater than or equal to 500


    In scope: Financial markets participants, issuers of financial products and large public interest entities meeting relevant size criteria

  • EU Taxonomy Regulation – Delegated Regulation specifying content and presentation of Article 8 – additional disclosures to apply


    EU Taxonomy Regulation: Additional requirements under Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 (non-financial statements) apply.

    In scope: Large non-financial public interest entities

  • EU Taxonomy Regulation – inclusion of nuclear and natural gas in Taxonomy


    EU Taxonomy Regulation – application of the proposed Complementary Climate Delegated Act, amending the EU Taxonomy Climate Delegated Act and setting out the conditions under which nuclear and natural gas can be included.

    In scope: Banks, investment firms, asset managers, insurers

  • SFDR – Regulatory Technical Standards to apply


    Disclosure Regulation (EU) 2019/2088 –sustainability-related disclosures in the financial sector ("SFDR"): Regulatory Technical Standards supplementing the SFDR requirements due to apply.

    In scope: Banks, investment firms, asset managers, insurers

  • Additional UK TCFD disclosure requirements in force for asset managers and owners, life and personal pension providers


    UK TCFD (FCA ESG rules) – UK-authorised asset managers and asset owners, life insurers and FCA-regulated pension providers 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. Publication deadline for first public disclosures 30/06/2024.

    In scope: UK-authorised asset managers and asset owners

    Qualifying condition: Balance sheet or assets greater than or equal to In-scope assets ≥£5bn (asset managers) or between £5bn and £25bn (asset owners)

  • CSRD enters into force


    Directive (EU) 2022/2464 on Corporate Sustainability Reporting in force.

    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.
  • End of transition period for implementation of the Register of Overseas Entities


    The Register of Overseas Entities came into force on 1 August 2022.  Before the end of the transition period on 31 January 2023, overseas entities that want to buy, sell or transfer qualifying property in the UK must register with Companies House and tell them who their registrable beneficial owners or managing officers are.  Overseas entities that acquired qualifying property on or after 1 January 1999 in England and Wales, or 8 December 2014 in Scotland, must notify Companies House about this.  Failure to register on time may lead to prosecution or civil financial penalties.  Overseas entities that fail to register will also find it difficult to sell, lease or raise charges over their land.

    In scope: All overseas entities holding, disposing of, charging or acquiring UK real estate; UK registered real estate owners contracting with an overseas entity.

  • Implementing MDR in the UK


    Regulations to come into force implementing in the UK the OECD's Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (MDR).  These regulations will replace the UK's similar DAC 6 rules currently in force. The Government has indicated that the MDR regulations will come into force "in the first half of 2023".

    In scope: All business organisations

  • New Modern Slavery Bill expected


    A new Modern Slavery Bill (proposing amendments to the Modern Slavery Act 2015) was announced in June 2022. Expected to be published in early 2023, the Bill is likely to introduce additional criminal offences designed to encourage businesses to address problem suppliers and make more accurate and complete statements.

    In scope: All business organisations of a certain size operating in the UK

    Qualifying condition: turnover greater than or equal to £36m

  • MEES Regulations Prohibition on letting properties with an EPC rating of F or less


    For commercial properties there will be a prohibition on continuing to let properties with an EPC rating of "F" or less. Whilst there is no express obligation to bring relevant properties up to a compliant standard under the MEES Regulations, local authorities will have enforcement powers, including the ability to impose penalties.

    In scope: All business organisations

  • Expected adoption publication of reporting standards under EU CSRD

    June 2023

    Expected date of adoption  of delegated acts adopting cross-sector reporting standards under the 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.
  • Expected publication of Sustainability Disclosure Requirements to apply to companies, financial institutions and occupational pension schemes. Effective date TBC


    Expected date for the FCA to publish its final rules on sustainability disclosure requirements (SDR) and investment labels.

    Current proposals suggest these will include requirements relating to sustainable investment product labels (three labels are proposed - sustainable focus, sustainable improvers and sustainable impact), naming and marketing rules (including a general ‘anti-greenwashing’ rule), consumer-facing product-level disclosure and detailed disclosures requirements for distributors of products.

    In scope: All UK-regulated investment firms and asset managers;, Occupational pension schemes (scope tbc).

  • Expected consultation on Future Buildings Standard


    Expected date of further consultation on the detailed technical aspects of the UK Government's Future Buildings Standard which will set out more stringent efficiency standards, to ensure that new buildings are 'zero carbon ready' from 2025.

    In scope: All real estate developers in the UK

  • Deadline for FCA ESG disclosures for largest asset managers and owners


    Deadline for UK-authorised asset managers with in-scope assets ≥£50bn and asset owners with in-scope assets ≥£25bn to make climate-related financial disclosures consistent with TCFD Recommendations.

    In scope: Largest UK-authorised asset managers and asset owners

    Qualifying conditions: Balance sheet or assets greater than or equal to - In-scope assets ≥£50bn (asset managers) or ≥£25bn (asset owners)

  • First principal adverse impacts statement under SFDR regulatory technical standards


    First principal adverse impacts statement under SFDR regulatory technical standards.

    In scope: Banks, investment firms, asset managers, insurers

  • UK Sustainability Disclosure Regime (SDR) and investment labels – final rules


    FCA intends its final rules on a new regime for Sustainability Disclosure Requirements (SDR) and investment labelling to start coming into force on a phased basis, starting with a general 'anti-greenwashing' rule applicable to all firms which will be effective on 30/06/2023. Requirements applicable to sustainable investment labels, consumer-facing disclosures, pre-contractual disclosures, naming and marketing rules, ongoing sustainability-related performance information, entity-level disclosures and distributors are expected to become effective on specified dates between 30/06/2024 and 30/06/2026.

    In scope: All regulated firms (as regards 'anti-greenwashing' rule), otherwise UK asset managers; "portfolio managers" (extends to capture private equity and other private market advisory activities).

  • Revised text of EU's Pay Transparency Directive expected


    It is currently expected that the EU's Pay Transparency Directive will oblige all companies to provide certain information to jobseekers/employees; and larger companies (current proposals are 250+ employees, but lowering this to 50 is being discussed) to publicly report on gender pay gap. Recent negotiations suggest a gender action plan where pay gap is higher than 2.5% may also be required.

    In scope: Larger businesses

    Qualifying conditions: Number of employees greater than or equal to 50

  • UK Biodiversity Net Gain requirement applies to new developments in UK


    The UK's Environment Act 2021 will require all new real estate developments to deliver a 10% 'biodiversity net gain' from November 2023, which will effectively become a requirement of its planning permission. This can be delivered through on-site or off-site measures or a combination.

    In scope: All businesses developing real estate in the UK

  • Deadline for Energy Efficiency Directive "Article 8" audit


    The EU Energy Efficiency Directive requires businesses to periodically audit their energy use and identify (and cost) potential energy savings. The deadline for audits varies across EU member states, but in most cases falls in late 2023.

    In scope: All business organisations of a certain size operating in the EU

    Qualifying conditions: Turnover greater than or equal to £50m, Balance sheet or assets greater than or equal to £43m, number of employees greater than or equal to 250

  • Deadline for Energy Savings Opportunity Scheme (ESOS) Audit


    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. Note that amendments expanding the scope of the UK regime are expected to take effect prior to this date, in early 2023. Scope of the audit may need careful consideration in context of any applicable franchise / management arrangements.

    In scope: All business organisations of a certain size operating in the UK

    Qualifying conditions: Turnover greater than or equal to £50m, Balance sheet or assets greater than or equal to £43m, number of employees greater than or equal to 250

  • EU Whistleblowing Directive to apply to small/medium private sector entities


    EU Whistleblowing Directive: national implementing legislation to apply to small/medium private sector entities operating in the EU, requiring them to have a whistleblowing policy.

    In scope: All business organisations of a certain size operating in the EU

  • Target date for global implementation of BEPS Pillar One rules


    End of 2023

    Target date for global implementation of most of the OECD's BEPS Pillar Two rules. The main plank of Pillar Two is the Global anti-Base Erosion rules (GloBE rules) which seek to establish a global minimum corporate tax rate of 15% for multinational enterprises (MNEs). The UK and EU are not expected to implement any aspects of Pillar Two before 31 December 2022

    In scope: Large MNEs. There are to be various exclusions, including for investment funds that are ultimate parent entities of an MNE group and pension funds (and any holding vehicles used by such funds).

  • Target date for global implementation of the OECD's BEPS Pillar One rules. The rules will reallocate 25% of the profits in excess of 10% of revenue of a multinational enterprise (MNE) to market jurisdictions where the MNE has a substantial engagement in that market, regardless of whether it has a physical presence there.


    Extremely large MNEs. There are to be exclusions for extractives and regulated financial services

    In scope: Global turnover above €20bn (reducing to €10bn in no earlier than seven years) and profitability above 10%

  • Expected application of EU Corporate Sustainability Reporting Directive to PIEs


    Expected application of EU Corporate Sustainability Reporting Directive to EU public interest entities ("PIEs"); sustainability reporting in 2025 for FY 2024

    In scope: PIEs and any entities already covered by the Non-Financial Reporting Directive 

  • EU Taxonomy Regulation – Delegated Regulation specifying content and presentation of Article 8 - additional disclosures to apply


    EU Taxonomy Regulation – Additional requirements under Delegated Regulation specifying content and presentation of information to be disclosed under Article 8 to apply.

    In scope: Large financial public interest entities

  • Start of first reporting period under CSRD for PIEs


    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. Greater than or equal to 500 employees.

  • Target date for global implementation of most of the BEPS Pillar Two rules

    2023 (but some rules to come into effect in 2024)

    Target date for global implementation of most of the OECD's BEPS Pillar Two rules. The main plank of Pillar Two is the Global anti-Base Erosion rules (GloBE rules) which seek to establish a global minimum corporate tax rate of 15% for multinational enterprises (MNEs). The UK and EU are not expected to implement any aspects of Pillar Two before 31 December 2022.

    In scope: Large MNEs. There are to be various exclusions, including for investment funds that are ultimate parent entities of an MNE group and pension funds (and any holding vehicles used by such funds).

    Qualifying condition: revenue >€750m

  • Start of first reporting period under CSRD for PIEs


    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: Employees greater than or equal to 500

  • Expected publication of first sector-specific reporting standards under CSRD


    Expected date of publication of first sector-specific reporting standards under the 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.
  • Additional deadline for FCA ESG disclosures for asset managers and owners


    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

  • Possible application of new regulatory framework for Heat Networks


    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

  • Parker ethnic diversity target for FTSE 250 in force


    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 on each FTSE 250 board.

    In scope: Listed companies – FTSE 250

  • Possible application of EU Corporate Sustainability Due Diligence Directive to certain EU and non-EU companies

    2024 (TBC)

    Possible application of EU Corporate Sustainability Due Diligence Directive imposing ESG due diligence requirements on certain EU and non-EU companies

    In scope:

    • "Group 1": Large EU companies and non-EU companies active in the EU;
    • "Group 2": EU "high impact" companies and non-EU "high impact" companies active in the EU [*Note: Group 2 excludes financial sector]

    Qualifying conditions:

    • Turnover
      Group 1: Greater than EUR 150m net global turnover
      Group 2: EUR 40m net global turnover
    • Number of employees
      Greater than 500 
      Greater than 250 (EU only)
  • TCFD governance and (later) disclosures may be required of smaller pension schemes


    Smaller occupational pension schemes may become subject to TCFD governance and disclosure requirements. This is subject to a review in late 2023 and a consultation in 2024.

    In scope: Pension trustees

  • Start of first reporting period under CSRD for large EU companies

    01 January 2025

    Application of CSRD  to large EU companies; sustainability reporting in 2026 for FY beginning on or after 01-01-2025

    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 40m, balance sheet or assets greater than or equal to EUR20m, greater than or equal to 250 employees

  • UK's Future Buildings Standard implemented


    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

  • Energy Performance Certificates to be harmonised across EU


    Energy Performance Certificates to be harmonised across the EU, and trigger to obtain a certificate to be extended to include major renovations (in addition to sales and leases).

    In scope: All businesses operating in the EU

  • Board diversity voluntary target


    FTSE Women Leaders report of 2022 recommends that by end of 2025:

    • FTSE 350 boards and leadership teams to have at least 40% women's representation and
    • FTSE 350 companies to have at least one women in the Chair, Senior Independent Director role and/or CEO or FD role

    In scope: Listed companies: FTSE 350

  • Start of first reporting period under CSRD for listed SMEs

    01 January 2026 (TBC)

    Application of CSRD  to listed SMEs; sustainability reporting in 2027 for FY beginning on or after 01-01-2026.

    In scope: Listed SMEs (except micro-enterprises)

  • EU board gender diversity requirements apply


    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: Turnover greater than or equal to EUR 50m, Balance sheet or assets greater than or equal to EUR 43m, greater than or equal to 250 employees

  • Application of CSRD to non-EU companies


    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

    Qualifying condition: Turnover greater than or equal to EUR 150m in the EU

  • All rented non-domestic buildings must achieve EPC Band B, where cost-effective


    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

  • Energy Performance of Buildings Directive to require new [buildings] to be zero emission


    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

  • New duty to prevent workplace sexual harassment

    TBC

    UK Government to introduce a positive duty on employers to prevent workplace sexual harassment, including harassment of staff by third parties. No date has been set.

     In scope: All businesses 

  • UK Government to introduce due diligence requirements to prevent forests and natural areas from being converted illegally into agricultural land

    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 

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.

See our 2021 Archived ESG timeline

Get in touch

For more information on People issues please contact Ed Mills.

For more information on Sustainable Finance issues, please contact Tim Lewis, Phil Bartram, Michael Raymond, Simon WitneyGeorge Weavil or Jonathan Gilmour.

For more information on Environment and Climate issues, please contact Doug Bryden.

For more information on Tax issues, please contact Madeline Gowlett or Hannah Manning.

For more information on Pensions issues, please contact Andy Lewis.

For more information on Governance issues, please contact Neal Watson or Doug Bryden.

For more information on Real Estate issues, please contact Alex Millar.

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