Our ESG timeline archive sets out past UK and EU legal and regulatory developments relating to ESG and wider sustainable business topics from January 2023 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 1 January to 31 December 2023. 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 2025.
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.
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 for 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
Draft UK guidelines regarding the assessment of competitor-to-competitor environmental/climate change cooperation under antitrust laws. Expected to be finalised by end of 2023
Similar to European Commission sustainability antitrust guidelines addressing sustainability cooperation between competitors, provides certain safe harbours for environmental and climate change agreements and indicates those ESG arrangements which are most likely to attract antitrust enforcement action. Indicates that informal guidance available. Arguably takes a more permissive approach than that of the European Commission, potentially offering individual exemptions on the basis of green benefits enjoyed by wider society. However, the UK authority's additional flexibility applies only as regards a subset of agreements specifically targeting environmental issues and, in particular, climate change. By contrast, the EU regulator's guidance provides greater flexibility under antitrust laws for a broader range of societal/sustainability goals.
In scope: Potentially any organisation which implements in the UK a sustainability collaboration, pledge or other industry arrangement (e.g. databases or accreditation schemes)
Themes: Climate change, environment and resources, Sustainable finance and ESG reporting
Implementing MDR in the UK
Regulations came into force implementing in the UK the OECD's Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (MDR). These regulations replaced the UK's similar DAC 6 rules that were previously in force.
In scope: All business organisations
Theme: Tax
New Modern Slavery Bill expected (but not yet published and no indication of publication date as at September 2023)
Expected early 2023 (but not published as at September 2023)
A new Modern Slavery Bill (proposing amendments to the Modern Slavery Act 2015) was announced in June 2022. It was expected to be published in early 2023, but as at September 2023 is not yet published and there has been no indication of when publication might be. 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
Integrity Council for the Voluntary Carbon Market launched its Core Carbon Principles and Programme-Level Assessment Framework
The Core Carbon Principles (CCPs) are a global benchmark for high-integrity carbon credits that set rigorous thresholds on disclosure and sustainable development. The CCPs provide a credible and rigorous means of identifying high-integrity carbon credits that create real, verifiable climate impact, based on the latest science and best practice.
In scope: All business organisations
Theme: Sustainable finance and ESG reporting
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
Draft provisions for sustainability-linked loans
LMA published draft provisions for sustainability linked loans
In scope: Lenders
Integrity Council for the Voluntary Carbon Market launched its new Claims Code of Practice
Claims Code of Practice provides companies with a rulebook to follow for making credible climate claims, helping to build market confidence in how they engage with Voluntary Carbon Markets.
In scope: All business organisations
Theme: Sustainable finance and ESG reporting
ISSB published its first global sustainability disclosure standards
The International Sustainability Standards Board (ISSB) published its first two sustainability standards: IFRS S1 on General Requirements for Disclosure of Sustainability-related Financial Information, and IFRS S2 on Climate-related Disclosures. These global sustainability disclosure standards are intended to improve trust and confidence in company disclosures about sustainability to inform investment decisions.
In scope: All business organisations
Theme: Sustainable finance and ESG reporting
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
First principal adverse impacts statement under SFDR regulatory technical standards.
In scope: Banks, investment firms, asset managers, insurers
Theme: Sustainable finance and ESG reporting
Revised text of EU's Pay Transparency Directive expected
Summer 2023
The EU's Pay Transparency Directive will oblige all companies to provide certain information to jobseekers/employees; and companies with 100 or more employees to publicly report on gender pay gap. Where the pay gap is higher than 5% employers will be required to conduct a pay assessment.
In scope: Larger businesses operating in the EU
Qualifying condition: Number of employees ≥ 50
Theme: People
Adoption of European Sustainability Reporting Standards under the EU Corporate Sustainability Reporting Directive (CSRD)
July 2023
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
UK's intention to develop UK Sustainability Disclosure Standards based on ISSB sustainability standards
The UK announces its intention to develop UK Sustainability Disclosure Standards based on ISSB sustainability standards.
In scope: All business organisations
Theme: Sustainable finance and ESG reporting, environment and resources
Publication of the Taskforce on Nature-related Financial Disclosures ("TNFD") recommendations
TNFD will be a voluntary framework for reporting of nature-related financial risks and opportunities, based closely on TCFD and using the same four pillars of Governance, Strategy, Risk Management and Metrics and Targets. Disclosures will be voluntary until mandated by regulations.
In scope: All business organisations
Theme: Climate change, environment and resources
Consultation on the UK's Green Taxonomy expected
Autumn 2023
UK government expected to consult on the UK Green Taxonomy.
In scope: All business organisations
Theme: Sustainable finance and ESG reporting
Higher-risk buildings must be registered with the Building Safety Regulator
Under the Building Safety Act 2022, owners of higher risk buildings that residents occupy or could occupy by 30 September 2023. Broadly, these are buildings of at least seven floors or at least 18 metres in height, that contain at least two residential units.
In scope: All businesses that own residential real estate in the UK
Theme: Built environment
UK Sustainability Disclosure Regime (SDR) and investment labels – final rules expected
Q4 2023
FCA to publish a policy statement on a new regime for Sustainability Disclosure Requirements (SDR) and investment labelling, including a general 'anti-greenwashing' rule.
In scope: All regulated firms (as regards 'anti-greenwashing' rule), otherwise UK asset managers and "portfolio managers" (which extends to capture private equity and other private market advisory activities).
Theme: Sustainable finance and ESG reporting
Term sheet for draft provisions for Sustainability-Linked loans
LMA published term sheet for draft provisions for Sustainability-Linked loans.
In scope: Lenders
UK Biodiversity Net Gain requirement applies to new developments in the UK
In scope: All business organisations of a certain size operating in the EU
Qualifying conditions:
Turnover: ≥£50m
Balance sheet or assets: ≥£43m
Employees: ≥250
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
End 2023
There are to be exclusions for extractives and regulated financial services. 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
Qualifying condition: Global turnover ≥€20bn (reducing to €10bn in no earlier than seven years) and profitability ≥10%
Theme: Tax
Target date for global implementation of most of the BEPS Pillar Two rules
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
Timeline by ESG theme
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 for 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
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.
Draft UK guidelines regarding the assessment of competitor-to-competitor environmental/climate change cooperation under antitrust laws. Expected to be finalised by end of 2023
Similar to European Commission sustainability antitrust guidelines addressing sustainability cooperation between competitors, provides certain safe harbours for environmental and climate change agreements and indicates those ESG arrangements which are most likely to attract antitrust enforcement action. Indicates that informal guidance available. Arguably takes a more permissive approach than that of the European Commission, potentially offering individual exemptions on the basis of green benefits enjoyed by wider society. However, the UK authority's additional flexibility applies only as regards a subset of agreements specifically targeting environmental issues and, in particular, climate change. By contrast, the EU regulator's guidance provides greater flexibility under antitrust laws for a broader range of societal/sustainability goals.
In scope: Potentially any organisation which implements in the UK a sustainability collaboration, pledge or other industry arrangement (e.g. databases or accreditation schemes)
Implementing MDR in the UK
Regulations came into force implementing in the UK the OECD's Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (MDR). These regulations replaced the UK's similar DAC 6 rules that were previously in force.
In scope: All business organisations
New Modern Slavery Bill expected (but not yet published and no indication of publication date as at September 2023)
Expected early 2023 (but not published as at September 2023)
A new Modern Slavery Bill (proposing amendments to the Modern Slavery Act 2015) was announced in June 2022. It was expected to be published in early 2023, but as at September 2023 is not yet published and there has been no indication of when publication might be. 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
Integrity Council for the Voluntary Carbon Market launched its Core Carbon Principles and Programme-Level Assessment Framework
The Core Carbon Principles (CCPs) are a global benchmark for high-integrity carbon credits that set rigorous thresholds on disclosure and sustainable development. The CCPs provide a credible and rigorous means of identifying high-integrity carbon credits that create real, verifiable climate impact, based on the latest science and best practice.
In scope: All business organisations
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
Draft provisions for sustainability-linked loans
LMA published draft provisions for sustainability linked loans
In scope: Lenders
Integrity Council for the Voluntary Carbon Market launched its new Claims Code of Practice
Claims Code of Practice provides companies with a rulebook to follow for making credible climate claims, helping to build market confidence in how they engage with Voluntary Carbon Markets.
In scope: All business organisations
ISSB published its first global sustainability disclosure standards
The International Sustainability Standards Board (ISSB) published its first two sustainability standards: IFRS S1 on General Requirements for Disclosure of Sustainability-related Financial Information, and IFRS S2 on Climate-related Disclosures. These global sustainability disclosure standards are intended to improve trust and confidence in company disclosures about sustainability to inform investment decisions.
In scope: All business organisations
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
Revised text of EU's Pay Transparency Directive expected
Summer 2023
The EU's Pay Transparency Directive will oblige all companies to provide certain information to jobseekers/employees; and companies with 100 or more employees to publicly report on gender pay gap. Where the pay gap is higher than 5% employers will be required to conduct a pay assessment.
In scope: Larger businesses operating in the EU
Qualifying condition: Number of employees ≥ 50
Adoption of European Sustainability Reporting Standards under the EU Corporate Sustainability Reporting Directive (CSRD)
July 2023
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
UK's intention to develop UK Sustainability Disclosure Standards based on ISSB sustainability standards
The UK announces its intention to develop UK Sustainability Disclosure Standards based on ISSB sustainability standards.
In scope: All business organisations
Publication of the Taskforce on Nature-related Financial Disclosures ("TNFD") recommendations
TNFD will be a voluntary framework for reporting of nature-related financial risks and opportunities, based closely on TCFD and using the same four pillars of Governance, Strategy, Risk Management and Metrics and Targets. Disclosures will be voluntary until mandated by regulations.
In scope: All business organisations
Consultation on the UK's Green Taxonomy expected
Autumn 2023
UK government expected to consult on the UK Green Taxonomy.
In scope: All business organisations
Higher-risk buildings must be registered with the Building Safety Regulator
Under the Building Safety Act 2022, owners of higher risk buildings that residents occupy or could occupy by 30 September 2023. Broadly, these are buildings of at least seven floors or at least 18 metres in height, that contain at least two residential units.
In scope: All businesses that own residential real estate in the UK
UK Sustainability Disclosure Regime (SDR) and investment labels – final rules expected
Q4 2023
FCA to publish a policy statement on a new regime for Sustainability Disclosure Requirements (SDR) and investment labelling, including a general 'anti-greenwashing' rule.
In scope: All regulated firms (as regards 'anti-greenwashing' rule), otherwise UK asset managers and "portfolio managers" (which extends to capture private equity and other private market advisory activities).
Term sheet for draft provisions for Sustainability-Linked loans
LMA published term sheet for draft provisions for Sustainability-Linked loans.
In scope: Lenders
UK Biodiversity Net Gain requirement applies to new developments in the UK
The UK's Environment Act 2021 will require all new real estate developments (apart from small sites) 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, buying statutory credits or a combination.
In scope: All businesses developing real estate in the UK
Deadline for Energy Efficiency Directive "Article 8" audit
In scope: All business organisations of a certain size operating in the EU
Qualifying conditions:
Turnover: ≥£50m
Balance sheet or assets: ≥£43m
Employees: ≥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
Qualifying conditions: Number of employees 50-249
Target date for global implementation of the OECD's BEPS Pillar One rules
End of 2023
There are to be exclusions for extractives and regulated financial services. 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
Qualifying condition: Global turnover ≥€20bn (reducing to €10bn in no earlier than seven years) and profitability ≥10%
Target date for global implementation of most of the BEPS Pillar Two Rules
End 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 legislation in the UK and EU implementing the income inclusion rule is expected to apply from 31 December 2023. EU legislation implementing the undertaxed profits rule is expected to apply from 31 December 2024. It is not clear when the UK will implement the UTPR; the government has previously stated that it will not be before 31 December 2024.
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).
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.
Get in touch
For more information on People issues please contact Ed Mills.
