UK sustainability regulation timeline · every regime, one calendar
The UK sustainability regulation timeline: every regime on one calendar
The UK sustainability regulation timeline is not one programme but a dozen instruments, each on its own clock, from SECR in 2019 to the last ESOS Phase 4 progress update in 2031.
Each date here is marked by what it is — in force, final but not yet in force, proposed, promised, or not happening — because the same year can hold all five.
1 January 2027 is the busiest single day: the FCA’s UK SRS rules and the UK carbon border adjustment mechanism both start.
The calendar
Every regime, date by date
“In force” binds today.
“Final” is fixed but starts later.
“Proposed” and “Promised” may change.
Expectations of a regulator are marked as such, because they are not rules.
| Date | Regime | What happens | Status |
|---|---|---|---|
| 1 Apr 2019 | SECR | Energy and carbon reporting in the directors’ report (SI 2018/1155) | In force |
| 6 Apr 2022 | Companies Act climate disclosure | Eight climate disclosures for financial years from this date (SI 2022/31) | In force |
| 12 Oct 2023 | TCFD | The task force disbands (TCFD) | Done |
| 6 Dec 2023 | ESOS Phase 4 | Compliance period begins (reg 4) | In force |
| 31 May 2024 | FCA SDR | Anti-greenwashing rule applies to all FCA-authorised firms (PS23/16) | In force |
| 31 Jul 2024 | FCA SDR | Sustainability labels available to qualifying fund managers | In force |
| 2 Dec 2024 | FCA SDR | Naming and marketing rules apply, at the latest | In force |
| 15 Jul 2025 | UK Green Taxonomy | Government decides not to proceed (response) | Not happening |
| 17 Sep 2025 | Transition plans | Consultation closes; no outcome yet (DESNZ) | Awaiting outcome |
| 2 Dec 2025 | FCA SDR | Entity-level reports due from the largest asset managers | In force |
| 3 Dec 2025 | PRA | SS5/25 replaces SS3/19 (PRA) | Expectations |
| 25 Feb 2026 | UK SRS | UK SRS S1 and S2 published (DBT) | Voluntary |
| 22 Jul 2026 | ESOS | Phase 4 amendments in force (SI 2026/701) | In force |
| 25 Sep 2026 | FCA ESG sourcebook | Product-level TCFD reports replaced (FCA 2026/59) | In force |
| 30 Sep 2026 | UK SRS | FCA final rules, PS26/19 (FCA) | Final |
| 10 Nov 2026 | EU ESRS | Revised standards in force (DR (EU) 2026/1563) | Final |
| 30 Nov 2026 | Corporate reporting | Modernising corporate reporting closes (consultation) | Proposed |
| 2 Dec 2026 | FCA SDR | Entity-level reports due from other managers with £5bn or more | In force |
| 5 Dec 2026 | ESOS Phase 3 | Second progress update on Phase 3 action plans | In force |
| 15 Dec 2026 | Assurance | ISSA (UK) 5000 effective (FRC) | Voluntary |
| 31 Dec 2026 | ESOS Phase 4 | Qualification date | In force |
| 1 Jan 2027 | UK SRS; UK CBAM | FCA rules apply to periods from this date; CBAM starts (FA 2026 Part 5) | Final |
| Spring 2027 | Companies Act climate disclosure | Post-implementation review due (MCR ¶148) | Promised |
| 5 Dec 2027 | ESOS Phase 4 | Notification of compliance due (EA) | In force |
| 2028 | UK SRS | First reports under the FCA rules | Final |
| 29 Jun 2028 | ESG ratings | Providing an ESG rating becomes a regulated activity (SI 2025/1349) | Final |
| 5 Dec 2028 | ESOS Phase 4 | Action plans due | In force |
| 1 Jan 2029 | UK SRS | Periods from this date: both FCA reliefs spent | Final |
| 5 Dec 2029–31 | ESOS Phase 4 | Three annual progress updates on the action plan | In force |
Already in force
What already binds, before any 2027 date
Three corporate regimes bind today, and none of them is a sustainability reporting standard.
SECR, in force since 1 April 2019, puts energy and carbon reporting into the directors’ report under Schedule 7 of SI 2008/410.
The Companies Act climate disclosures in section 414CB apply to financial years beginning on or after 6 April 2022, for companies with more than 500 employees that are traded, banking, insurance or AIM companies or have turnover above £500 million.
ESOS Phase 4 has run since 6 December 2023 and is judged on 31 December 2026; the details are on the ESOS hub and ESOS Phase 4 thresholds.
For financial firms, the FCA’s SDR rules have applied in stages since 31 May 2024, and the PRA’s SS5/25 has set its climate-risk expectations since 3 December 2025 — expectations, not a reporting duty.
The government decided on 15 July 2025 not to take the UK Green Taxonomy forward, and the transition plan consultation has produced no outcome.
The wider picture is on the UK sustainability regulation landscape, nature on nature-related disclosures, and the transition-plan position on UK transition plan regulation.
A UK green taxonomy: not proceeding.
A duty to have a climate transition plan: none.
A UK nature-disclosure mandate: none proposed.
2026
2026: the year the listing rules were settled
2026 produced the standards on 25 February (DBT) and the FCA’s final rules on 30 September.
It also amended ESOS Phase 4 from 22 July (SI 2026/701), without changing its qualification thresholds.
On 25 September, a separate FCA instrument replaced the product-level TCFD reports of asset managers and asset owners (Handbook Notice 144).
The government’s Modernising corporate reporting consultation proposes moving SECR out of the directors’ report without changing who reports, and says a consultation on SECR and ESOS is intended later in 2026.
What 2026 means for UK SRS in particular is on UK SRS in 2026.
| Date | Still to come in 2026 |
|---|---|
| 28 Oct | FCA draft TN 803.1 comments close |
| 10 Nov | Revised ESRS in force |
| 30 Nov | Modernising corporate reporting closes |
| 2 Dec | SDR entity reports: managers with £5bn+ |
| 15 Dec | ISSA (UK) 5000 effective |
| 31 Dec | ESOS Phase 4 qualification |
2027
2027: the heaviest year on the calendar
From 1 January 2027 listed companies in five categories report against UK SRS on a comply-or-explain basis (PS26/19), with the first reports published in 2028.
The UK carbon border adjustment mechanism starts the same day under Finance Act 2026 Part 5; it is a tax, not a reporting standard.
The EU’s revised ESRS apply to financial years beginning on or after 1 January 2027 (DR (EU) 2026/1563), reaching a UK group through its EU undertakings.
ESOS Phase 4 ends with notification of compliance by 5 December 2027 (Environment Agency); how it differs from Phase 3 is on ESOS Phase 3 vs Phase 4.
Your own UK SRS first period is on the UK SRS deadline.
| 2027 | Who it reaches |
|---|---|
| 1 Jan — UK SRS listing rules | Listed companies in UKLR 6, 14, 15, 16, 22 |
| 1 Jan — UK CBAM | The goods and sectors the Act lists |
| FY2027 — revised ESRS | EU undertakings in scope, including UK groups’ EU subsidiaries |
| Spring — CFD review due | Companies under s.414CB |
| 5 Dec — ESOS Phase 4 notification | Large undertakings and their groups |
2028 onwards
2028 to 2031: first reports, reliefs spent, action plans due
The first UK SRS reports under the FCA rules appear in 2028, in annual financial reports for periods that began in 2027.
Periods beginning in 2028 lose the Scope 3 relief; periods beginning from 1 January 2029 lose the UK SRS S1 relief too.
Measuring Scope 3 before that is covered on Scope 3 under UK SRS.
Providing an ESG rating becomes a regulated activity on 29 June 2028 (SI 2025/1349).
ESOS Phase 4 action plans are due by 5 December 2028, with progress updates each December from 2029 to 2031.
Beyond those dates, nothing further is proposed: no private-company UK SRS date, no taxonomy, and no transition-plan duty; the plans themselves are discussed on transition plans under UK SRS.
When the FCA’s Scope 3 relief ends for periods beginning in 2028, Scope 3 joins the rest of UK SRS on comply or explain. It is not made compulsory.
One company, several clocks
Which clocks run for which company, and how long the work takes
A listed group can sit inside four of these regimes at once, each with its own threshold, regulator and date.
The instruments do not share tests: SECR’s is two of three limits, ESOS’s is either-or, and the Companies Act duty needs employees and turnover or company type together.
No regulator publishes how long a sustainability report takes to prepare; the only government measurement is for SECR, where the 2026 evaluation found 94 hours of internal staff time a year.
The SECR post-implementation review recommends keeping the regime with amendments, and the Regulatory Policy Committee rated it fit for purpose on 15 May 2026.
The government’s wider framing of green finance is its green finance strategy, updated in 2023; the standards themselves remain voluntary outside the listing rules.
What the standards ask for is on what is UK SRS, and preparing for them on UK SRS compliance.
| Company | Clocks likely to run |
|---|---|
| Large UK private company | SECR; ESOS; possibly s.414CB |
| Listed commercial company | SECR; ESOS; s.414CB; UK SRS comply or explain from 2027 |
| UK group with an EU subsidiary in CSRD scope | The UK regimes, plus ESRS for the subsidiary |
| Asset manager | FCA SDR and ESG sourcebook; UK SRS only if listed in scope |
Frequently asked
UK sustainability regulation: the questions asked
What is the UK sustainability regulation timeline?
SECR has applied since 1 April 2019 and the Companies Act climate disclosures since financial years beginning on or after 6 April 2022.
The FCA’s anti-greenwashing rule has applied since 31 May 2024.
ESOS Phase 4 qualification is judged on 31 December 2026, with notification due by 5 December 2027.
The FCA’s UK SRS listing rules and the UK carbon border adjustment mechanism both start on 1 January 2027, and providing an ESG rating becomes a regulated activity on 29 June 2028.
What UK sustainability regulations start in 2027?
The FCA’s rules requiring listed companies in five categories to report against UK SRS on a comply-or-explain basis apply to accounting periods beginning on or after 1 January 2027.
The UK CBAM starts on the same day.
ESOS Phase 4 notifications are due by 5 December 2027, and the revised EU ESRS apply to financial years beginning in 2027 for EU undertakings, including a UK group’s EU subsidiaries in scope.
Is UK SRS mandatory in 2027?
No. From accounting periods beginning on or after 1 January 2027, listed companies in UKLR 6, 14, 15, 16 and 22 must report against UK SRS or explain why they have not.
For everyone else the standards remain voluntary.
Does the UK have a green taxonomy?
No. The government decided on 15 July 2025 not to take the UK Green Taxonomy forward.
Do UK companies have to publish a transition plan?
No UK entity is under a legal duty to have a climate transition plan.
Listed companies in UKLR 6, 16 and 22 must say whether they have published one, and where, or why not.
The government’s consultation on transition plan requirements closed on 17 September 2025 with no outcome published.
How long does a sustainability statement in the UK take to complete?
No regulator publishes a figure for UK SRS or for a sustainability statement generally.
The only government measurement is for SECR: its 2026 evaluation found a mean of 94 hours of internal staff time a year and a mean ongoing cost of £7,100.
What the rules fix is when a report must be public, not how long it takes.
When is the ESOS Phase 4 deadline?
Qualification is judged on 31 December 2026, and notification of compliance is due by 5 December 2027.
Phase 4 action plans are due by 5 December 2028, with progress updates each December from 2029 to 2031.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2018/1155 — the instrument that created SECR
In force 1 April 2019.
- legislation.gov.ukSI 2008/410 Schedule 7 (directors’ report content, including SECR)
- legislation.gov.ukSI 2022/31 — climate-related financial disclosure
Financial years beginning on or after 6 April 2022.
- legislation.gov.ukCompanies Act 2006, section 414CB
- legislation.gov.ukSI 2014/1643, regulation 4 — ESOS compliance periods
Phase 4: 6 December 2023 to 5 December 2027; qualification date 31 December 2026.
- legislation.gov.ukSI 2026/701 — ESOS (Amendment) Regulations 2026
In force 22 July 2026.
- Environment AgencyHow to comply with ESOS Phase 4
The milestone table: action plans by 5 December 2028; progress updates 2029–2031.
- Financial Conduct AuthorityPS23/16 — Sustainability Disclosure Requirements (SDR) and investment labels
Anti-greenwashing rule from 31 May 2024; labels, naming and marketing, and disclosures.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Comply or explain against UK SRS for periods beginning on or after 1 January 2027.
- Financial Conduct AuthorityHandbook Notice 144
FCA 2026/59 in force 25 September 2026: product-level TCFD reporting replaced.
- Prudential Regulation AuthoritySS5/25 — Enhancing banks’ and insurers’ approaches to managing climate-related risks
Commenced 3 December 2025, replacing SS3/19 in its entirety. Expectations, not rules.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026, voluntary for any entity.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
7 September to 30 November 2026.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF)
¶¶147–150: CFD review by spring 2027; SECR’s location; a SECR and ESOS consultation promised.
- Department for Energy Security and Net ZeroIndependent evaluation of SECR, 29 January 2026
Mean ongoing cost £7,100 a year; 94 hours of internal time.
- Department for Energy Security and Net ZeroPost-Implementation Review of the SECR Regulations 2018 (PDF)
RPC opinion “fit for purpose”, 15 May 2026.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements
Consultation closed 17 September 2025; no outcome published.
- HM GovernmentUK Green Taxonomy: consultation response
The taxonomy was not taken forward (15 July 2025).
- HM GovernmentGreen finance strategy (2019, updated 2023)
Mobilising green investment: the 2023 strategy.
- legislation.gov.ukFinance Act 2026, Part 5 — UK carbon border adjustment mechanism
Starts 1 January 2027.
- legislation.gov.ukSI 2025/1349 — FSMA 2000 (Regulated Activities) (ESG Ratings) Order 2025
Providing an ESG rating becomes a regulated activity on 29 June 2028.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS
In force 10 November 2026; financial years beginning on or after 1 January 2027.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
Effective for periods beginning on or after 15 December 2026.
- TCFDTCFD recommendations
The task force disbanded on 12 October 2023.