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Archive: ESG timeline (from January 2021)

Overview

Our ESG timeline archive sets out past UK and EU legal and regulatory developments relating to ESG and wider sustainable business topics from January 2021 onwards. As with the main timeline, the timeline archive can be filtered according to your business type or the relevant ESG theme.

This timeline archive covers the period from January 2021. Please refer back to our full ESG timeline for more recent and expected updates UK and EU ESG-related legal and regulatory developments

The timeline will be maintained. The last major update was in January 2023. 

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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.

  • UK premium-listed companies subject to TCFD disclosure requirements


    TCFD – climate-related disclosure requirements apply to commercial companies with a UK premium listing for accounting periods beginning on or after 01/01/2021: see our briefing Consultation on mandatory climate reporting: the building of a new sustainable financial system.

    In scope: UK premium-listed companies

    Theme: Sustainable Finance and ESG reporting

  • A UK Emissions Trading Scheme (UK ETS) replaced the UK's participating in the EU ETS.


    A UK Emissions Trading Scheme (UK ETS) replaced the UK's participating in the EU ETS.

    In scope: Stationary installations holding (or liable to hold): (i) a greenhouse gas emissions permit, including power generators; certain large industrial premises and manufacturers, including food processing plants; certain public sector facilities; and (ii) an excluded installation emissions permit (small emitters and hospitals)

    Theme: Climate change, environment and resources 

  • New immigration regime takes effect


    New immigration regime: free movement for nationals of the European Economic Area (EEA) and Switzerland ended and the new immigration regime took effect. Non-British/Irish nationals not covered by the UK/EU Withdrawal Agreement generally require visas for all but short-term visits to the UK, and no longer have an automatic right to work.

    In scope: All business organisations with EEA and/or Swiss workers subject to immigration rules.

    Theme: People

  • DAC6 - start of "30-day window"


    Start of the "30 day" window for making the first reports under the new DAC6 regime. The deadline for reports was delayed as a response to the Covid-19 pandemic. Under the regime, intermediaries or, in some cases, taxpayers themselves, are required to report cross-border arrangements which satisfy certain hallmarks.

    [Note: Following Brexit, scope of reporting in UK restricted to disclosure of limited situations concerning the automatic exchange of information and beneficial ownership. DAC 6 expected to be replaced in the first half of 2023 by a similar regime, based on the OECD's mandatory disclosure rules under BEPS Action 12 (see below)].

    In scope: All business organisations

    Theme: Tax

  • EU Conflict Minerals Regulation (which applies to importers of certain minerals) in force


    In scope: Business organisations importing any "conflict minerals" (tin, tantalum and tungsten and their ores, and gold, so-called "3TG" minerals)

    Theme: Climate change, environment and resources

  • Closure of EC consultation on sustainable corporate governance


    Closure of the European Commission consultation on a potential EU-wide initiative on sustainable corporate governance.

    In scope: All business organisations

    Theme: Sustainable Finance and ESG reporting

  • Pensions Climate Risk Industry Group guidance on TCFD disclosures published


    Non-statutory guidance for occupational pension scheme trustees on assessing, managing and reporting climate-related risks in line with the TCFD (Taskforce on Climate-Related Financial Disclosures) was published by the Pensions Climate Risk Industry Group.

    In scope: Pension scheme trustees

    Theme: Sustainable Finance and ESG reporting

  • SFDR – majority of disclosure obligations apply to in-scope entities


    Disclosure Regulation (EU) 2019/2088 – key applicable dates for sustainability-related disclosures in the financial sector ("SFDR"): The majority of the disclosure obligations apply: sustainability-related disclosures on the website for in-scope entities and in relevant pre-contractual information for products in market (additional disclosure requirements for larger in scope participants required from 30 June 2021).

    Obligations depend on classification, ranging from Article 6 products (no obligations, any product which is not in Articles 8 or 9); Article 8 products (promote environmental and/or social characteristics); Article 9 (exclusively sustainable investments).

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

    Theme: Sustainable Finance and ESG reporting

  • SECR reporting required for financial years ending on or after 31 Dec 2020


    Streamlined Energy and Carbon Reporting ("SECR") – latest year-end date for in scope entities to include SECR reporting in annual reports.

    In scope: All quoted companies, all business organisations of a certain size

    Qualifying conditions:

    • Turnover greater than or equal to £36m
    • Balance sheet or assets greater than or equal to £18m
    • Number of employees greater than or equal to 250

    Theme: Climate change, environment and resources

  • New Off-Payroll Working Rules in force


    New off-payroll working rules came into force following delays due to the Covid-19 pandemic.

    In scope: All public sector entities; Large and medium-sized businesses which meet 2 or more of the qualifying conditions

    Theme: Tax

  • Proposal for EU Corporate Sustainability Reporting Directive for large companies and most listed companies


    Proposal for EU Corporate Sustainability Reporting Directive to expand sustainability reporting requirements and extend to all large companies and most listed companies.

    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.

    [*Note: other listed companies are already subject to equivalent requirements in the Non-Financial Reporting Directive]

    Theme: Sustainable finance and ESG reporting

  • European Commission adopts Zero Pollution Action Plan


    European Commission adopted its "zero pollution action plan" (part of the EU Green Deal) with a view to promoting the protection of air, soil and water.

    In scope: All business organisations

    Theme: Climate change, environment and resources

  • Publication of statutory guidance for in scope pension scheme trustees on climate risk reporting


    Statutory guidance published by the Government on governance and reporting of climate change risk for in-scope occupational pension scheme trustees from 1 October 2021

    In scope: In scope pension scheme trustees

    Themes: Sustainable finance and ESG reporting

  • Deadline for EEA and Swiss nationals covered by the withdrawal agreement between the UK and EU to apply for UK residence


    EU Settlement Scheme: deadline by which EEA and Swiss nationals covered by the withdrawal agreement between the UK and EU must have applied for UK residence status.

    In scope: All business organisations with EEA and/or Swiss workers subject to immigration rules

    Theme: People

  • TCFD disclosures required of largest pension schemes


    TCFD – Since 1 October 2021, trustees of occupational pension schemes with £5billion+ in assets, authorised master trusts and collective money purchase schemes are required under Pension Schemes Act 2021 regulations to comply with enhanced climate-related governance requirements, with the first public disclosures to be made within seven months of the current scheme year end

    In scope: Occupational pension schemes (£5bn+) and authorised master trust and collective money purchase pension schemes

    Qualifying condition:

    • Pension scheme assets greater than £5bn

    Theme: Sustainable finance and ESG reporting

  • Announcement of Sustainability Disclosure Requirements to apply to companies, financial institutions and occupational pension schemes - Effective date TBC


    HM Treasury published Greening Finance: A Roadmap to Sustainable Investing, which sets out the Government's strategy to align the financial system with the UK's commitment to net zero.  New Sustainability Disclosure Requirements (SDR) will contain a requirement for companies, financial institutions and occupational pension schemes to make additional sustainability disclosures, which will expand upon the existing TCFD climate-related disclosures framework. A new UK Green Taxonomy is also proposed.

    In scope: Companies, some financial institutions, and occupational pension schemes

    Theme: Sustainable finance and ESG reporting

  • UK hosted 26th UN Climate Change Conference of the Parties (COP26)

    1 - 21 November 2021

    UK hosted the 26th UN Climate Change Conference of the Parties (COP26) in Glasgow.

    In scope: All business organisations

    Theme: Climate change, environment and resources

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


    UK Sustainability Regime: FCA published discussion paper (DP21/4) on Sustainability Disclosure Requirements and investment product labels.

    In scope: UK asset managers and certain FCA-regulated asset owners

    Theme: Sustainable finance and ESG reporting

  • New Office for Environmental Protection took charge of UK environment matters

    November 2021

    A new environmental watchdog, the Office for Environmental Protection ("OEP") took over environmental governance matters from the European Commission and ECJ under the new Environment Act 2021.

    The OEP's stated principal objectives are to contribute to environmental protection and hold the UK Government to account on environmental commitments.

    In scope: All business organisations

    Themes: Climate change, environment and resources

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


    Guidance for trustees of in-scope occupational pension schemes on the governance and reporting of climate-related risks and opportunities published by the Pensions Regulator.

    In scope: In-scope pension scheme trustees

    Theme: Sustainable finance and ESG reporting

  • EU Whistleblowing Directive in force


    Whistleblowing Directive: deadline for EU member states to bring into force legislation transposing new Whistleblowing Directive, which will require employers to have a whistleblowing policy, with large organisations required to comply first.

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

    Qualifying condition: Number of employees greater than or equal to 250 initially

    Theme: People

  • Closure of IFRS Foundation consultation on global sustainability standards


    Closure of IFRS Foundation consultation on the need for global sustainability standards.

    [Note: In Nov 2021, the IFRS Foundation announced the formation of the International Sustainability Standards Board. Consolidation of the existing Climate Disclosure Standards Board into the ISSB took place in January 2022 followed by the Value Reporting Foundation August 2022.]

    In scope: All business organisations

    Theme: Sustainable finance and ESG reporting

  • Parker ethnic diversity target in force


    Parker ethnic diversity target: Target date for companies to meet the Parker Review aim of there being at least one director of colour on each FTSE 100 board.

    In scope: Listed companies – FTSE 100

    Theme: People

Timeline by ESG theme

  • UK premium-listed companies subject to TCFD disclosure requirements


    TCFD – climate-related disclosure requirements apply to commercial companies with a UK premium listing for accounting periods beginning on or after 01/01/2021: see our briefing Consultation on mandatory climate reporting: the building of a new sustainable financial system.

    In scope: UK premium-listed companies 

  • A UK Emissions Trading Scheme (UK ETS) replaced the UK’s participation in the EU ETS


    A UK Emissions Trading Scheme (UK ETS) replaced the UK’s participation in the EU ETS.

    In scope: Stationary installations holding (or liable to hold): (i) a greenhouse gas emissions permit, including power generators; certain large industrial premises and manufacturers, including food processing plants; certain public sector facilities; and (ii) an excluded installation emissions permit (small emitters and hospitals)

  • New immigration regime takes effect


    New immigration regime: free movement for nationals of the European Economic Area (EEA) and Switzerland ended and the new immigration regime took effect. Non-British/Irish nationals not covered by the UK/EU Withdrawal Agreement generally require visas for all but short-term visits to the UK, and no longer have an automatic right to work.

    In scope: All business organisations with EEA and/or Swiss workers subject to immigration rules.

  • DAC6 - start of "30-day window"


    Start of the "30 day" window for making the first reports under the new DAC6 regime. The deadline for reports was delayed as a response to the Covid-19 pandemic. Under the regime, intermediaries or, in some cases, taxpayers themselves, are required to report cross-border arrangements which satisfy certain hallmarks.

    [Note: Following Brexit, scope of reporting in UK restricted to disclosure of limited situations concerning the automatic exchange of information and beneficial ownership. DAC 6 expected to be replaced in the first half of 2023 by a similar regime, based on the OECD's mandatory disclosure rules under BEPS Action 12 (see below)].

    In scope: All business organisations

  • EU Conflict Minerals Regulation (which applies to importers of certain minerals) in force


    EU Conflict Minerals Regulation (which applies to importers of certain minerals) comes into force.

    In scope: Business organisations importing any "conflict minerals" (tin, tantalum and tungsten and their ores, and gold, so-called "3TG" minerals)

  • Closure of EC consultation on sustainable corporate governance


    Closure of the European Commission consultation on a potential EU-wide initiative on sustainable corporate governance.

    In scope: All business organisations

  • Pensions Climate Risk Industry Group guidance on TCFD disclosures published


    Non-statutory guidance for occupational pension scheme trustees on assessing, managing and reporting climate-related risks in line with the TCFD (Taskforce on Climate-Related Financial Disclosures) was published by the Pensions Climate Risk Industry Group.

    In scope: Pension scheme trustees

  • SFDR – majority of disclosure obligations apply to in-scope entities


    Disclosure Regulation (EU) 2019/2088 – key applicable dates for sustainability-related disclosures in the financial sector ("SFDR"): The majority of the disclosure obligations apply: sustainability-related disclosures on the website for in-scope entities and in relevant pre-contractual information for products in market (additional disclosure requirements for larger in scope participants required from 30 June 2021).

    Obligations depend on classification, ranging from Article 6 products (no obligations, any product which is not in Articles 8 or 9); Article 8 products (promote environmental and/or social characteristics); Article 9 (exclusively sustainable investments).

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

  • SECR reporting required for financial years ending on or after 31 Dec 2020


    Streamlined Energy and Carbon Reporting ("SECR") – latest year-end date for in scope entities to include SECR reporting in annual reports.

    In scope: All quoted companies, All business organisations of a certain size

    Qualifying conditions:

    • Turnover greater than or equal to £36m
    • Balance sheet or assets greater than or equal to £18m
    • Number of employees greater than or equal to 250

  • New Off-Payroll Working Rules in force


    New off-payroll working rules came into force following delays due to the Covid-19 pandemic.

    In scope: All public sector entities; Large and medium-sized businesses which meet 2 or more of the qualifying conditions

  • Proposal for EU Corporate Sustainability Reporting Directive for large companies and most listed companies


    Proposal for EU Corporate Sustainability Reporting Directive to expand sustainability reporting requirements and extend to all large companies and most listed companies.

    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.

      [*Note: other listed companies are already subject to equivalent requirements in the Non-Financial Reporting Directive]

  • European Commission adopts Zero Pollution Action Plan


    European Commission adopted its "zero pollution action plan" (part of the EU Green Deal) with a view to promoting the protection of air, soil and water.

    In scope: All business organisations

  • Publication of statutory guidance for in scope pension scheme trustees on climate risk reporting


    Statutory guidance published by the Government on governance and reporting of climate change risk for in-scope occupational pension scheme trustees from 1 October 2021

    In scope: In scope pension scheme trustees

  • Deadline for EEA and Swiss nationals covered by the withdrawal agreement between the UK and EU to apply for UK residence.


    EU Settlement Scheme: deadline by which EEA and Swiss nationals covered by the withdrawal agreement between the UK and EU must have applied for UK residence status.

    In scope: All business organisations with EEA and/or Swiss workers subject to immigration rules

  • TCFD disclosures required of largest pension schemes


    TCFD – Since 1 October 2021, trustees of occupational pension schemes with £5billion+ in assets, authorised master trusts and collective money purchase schemes are required under Pension Schemes Act 2021 regulations to comply with enhanced climate-related governance requirements, with the first public disclosures to be made within seven months of the current scheme year end

    In scope: Occupational pension schemes (£5bn+) and authorised master trust and collective money purchase pension schemes

    Qualifying condition: Pension scheme assets greater than £5bn

  • Announcement of Sustainability Disclosure Requirements to apply to companies, financial institutions and occupational pension schemes - Effective date TBC


    HM Treasury published Greening Finance: A Roadmap to Sustainable Investing, which sets out the Government's strategy to align the financial system with the UK's commitment to net zero.  New Sustainability Disclosure Requirements (SDR) will contain a requirement for companies, financial institutions and occupational pension schemes to make additional sustainability disclosures, which will expand upon the existing TCFD climate-related disclosures framework. A new UK Green Taxonomy is also proposed.

    In scope: Companies, some financial institutions, and occupational pension schemes

  • UK hosted 26th UN Climate Change Conference of the Parties (COP26)


    UK hosted the 26th UN Climate Change Conference of the Parties (COP26) in Glasgow.

    In scope: All business organisations

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


    UK Sustainability Regime: FCA published discussion paper (DP21/4) on Sustainability Disclosure Requirements and investment product labels.

    In scope: UK asset managers and certain FCA-regulated asset owners

  • New Office for Environmental Protection took charge of UK environment matters

    November 2021

    A new environmental watchdog, the Office for Environmental Protection ("OEP") took over environmental governance matters from the European Commission and ECJ under the new Environment Act 2021.

    The OEP's stated principal objectives are to contribute to environmental protection and hold the UK Government to account on environmental commitments.

    In scope: All business organisations

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


    Guidance for trustees of in-scope occupational pension schemes on the governance and reporting of climate-related risks and opportunities published by the Pensions Regulator.

    In scope: In-scope pension scheme trustees

  • EU Whistleblowing Directive in force


    Whistleblowing Directive: deadline for EU member states to bring into force legislation transposing new Whistleblowing Directive, which will require employers to have a whistleblowing policy, with large organisations required to comply first.

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

    Qualifying condition: Number of employees greater than or equal to 250 initially

  • Closure of IFRS Foundation consultation on global sustainability standards


    Closure of IFRS Foundation consultation on the need for global sustainability standards.

    [Note: In Nov 2021, the IFRS Foundation announced the formation of the International Sustainability Standards Board. Consolidation of the existing Climate Disclosure Standards Board into the ISSB took place in January 2022 followed by the Value Reporting Foundation in August 2022.]

    In scope: All business organisations

  • Parker ethnic diversity target in force


    Parker ethnic diversity target: Target date for companies to meet the Parker Review aim of there being at least one director of colour on each FTSE 100 board.

    In scope: Listed companies – FTSE 100

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.

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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 Witney, George 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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