UK ESG reporting deadlines for 2026 and 2027

Most ESG deadlines arrive with everyone unprepared. Not because they were secret. The qualifying date, the reporting period and the filing date are rarely the same day. A 2027 rule is a 2026 decision.

This is the calendar our ESG consulting team works from with clients. It covers every UK regime with a hard date between September 2026 and the end of 2027, plus the EU rules that reach UK groups. Each carries a status. Mandatory means the law is made. Proposed means a regulator has published draft rules and not yet finalised them. Voluntary means it binds you only once you sign up.

We checked every date against its primary source on 8 September 2026. The biggest change had landed the day before. The government published its Modernising Corporate Reporting consultation on 7 September 2026 and it proposes no date for private company UK SRS reporting.

UK ESG reporting calendar

Date	Regime	What happens	Status
16 September 2026	CDP	Scoring deadline for the 2026 disclosure cycle	Voluntary
Autumn 2026	FCA	Policy statement on the UK SRS listing rules (CP26/5)	Proposed
30 November 2026	Modernising Corporate Reporting	Government consultation closes	Consultation
2 December 2026	FCA SDR	First entity-level sustainability reports, asset managers with £5bn to £50bn under management	Mandatory
5 December 2026	ESOS Phase 3	Second annual progress update, with director sign-off	Mandatory
15 December 2026	ISSA (UK) 5000	Sustainability assurance standard effective for periods beginning on or after this date	Voluntary
30 December 2026	EUDR	Deforestation rules apply to large and medium operators placing goods on the EU market	Mandatory (EU)
31 December 2026	ESOS Phase 4	Qualification date	Mandatory
1 January 2027	UK SRS S2	Proposed listing rules apply to accounting periods beginning on or after this date	Proposed
1 January 2027	UK CBAM	Carbon levy on imported aluminium, cement, fertiliser, hydrogen, iron and steel	Mandatory
1 January 2027	UK ETS	Second free allocation period begins and free allocation for CBAM sectors starts to phase out	Mandatory
1 January 2027	PPN 026	New Social Value Model for central government procurements of £1m and above	Mandatory
1 January 2027	CSRD	First reporting year for EU companies still in scope, on the simplified ESRS	Mandatory (EU)
1 February 2027	SBTi	Corporate Net-Zero Standard V2.0 takes effect	Voluntary
1 February 2027	EU CBAM	Certificate sales begin	Mandatory (EU)
19 March 2027	CSRD	Member state deadline to transpose Omnibus I	EU
1 April 2027	NHS	2027 Carbon Reduction Plan standard for contracts of £5m a year and all new frameworks	Mandatory
Spring 2027	CFD	Government review of Companies Act climate-related financial disclosures concludes	Review
30 June 2027	EUDR	Deforestation rules apply to micro and small operators	Mandatory (EU)
30 September 2027	EU CBAM	First annual declaration, covering 2026 imports	Mandatory (EU)
5 December 2027	ESOS Phase 4	Compliance notification to the Environment Agency	Mandatory

Two dates fall just outside the window. 31 January 2028 is the UK CBAM registration deadline for 2027 liability and the last day to submit an SBTi target under the current standard.

UK SRS - the FCA decision due in autumn 2026

Status. Voluntary today. Proposed as mandatory for UK-listed companies from accounting periods beginning on or after 1 January 2027.

The Department for Business and Trade published the final UK Sustainability Reporting Standards, UK SRS S1 and S2, on 25 February 2026. Any company can use them now. Nothing forces you to until a regulator says so.

The FCA is that regulator for listed companies. Its consultation CP26/5, published 30 January 2026, proposes replacing the TCFD listing rules with UK SRS for commercial companies, secondary listings, depositary receipts, non-equity issuers and the transition category. Investment funds and shell companies are out. Around 515 issuers get the full requirements.

What the FCA proposed

UK SRS S2, the climate standard, becomes mandatory. Scope 3 emissions are comply or explain, permanently, with a one-year deferral available at the start. The non-climate parts of S1 are comply or explain with a two-year deferral. Assurance is not required, but you must say whether you obtained it and from whom. A transition plan is not required, but you must say whether you have one and where it is published.

The FCA said it would publish its policy statement in autumn 2026. It had not done so as of 8 September 2026. The FCA's own Listing Authority Advisory Panel argued for a voluntary period first. Until the final rules are made, periods beginning before 1 January 2027 stay on the TCFD listing rules and the Companies Act climate disclosures.

Map the date to your year end

The 1 January 2027 date attaches to your accounting period, not the calendar. A 31 December year end reports on FY2027 in spring 2028. A 31 March year end starts its first UK SRS period on 1 April 2027 and reports in mid-2028. A 30 June year end begins on 1 July 2027.

Private companies

There is no date. The Modernising Corporate Reporting consultation, published 7 September 2026 and open until 30 November, asks how UK SRS should be reflected in the Companies Act and proposes a new "very large" company category. It does not propose to mandate UK SRS for private companies and it sets no timetable. Any 2028 date you have seen for private companies is commentary, not policy.

What to do in 2026

Run a gap assessment of your last TCFD statement against S2. In our experience the governance narrative and the scenario analysis carry over. The gaps sit in the metrics, in the industry-based disclosures and in the evidence trail behind the numbers an assurer will ask for.

ESOS - one date in 2026 and one in 2027

Status. Mandatory. Phase 3 and Phase 4 overlap in 2026.

The last Phase 3 obligation is the second annual progress update, due to the Environment Agency by 5 December 2026 with board-level director sign-off. After that, you report progress against your Phase 3 action plan inside your Phase 4 assessment, with an explanation for anything you committed to and did not do.

Phase 4 qualification turns on your position at 31 December 2026. You qualify with 250 or more UK employees, or with turnover above £44m and a balance sheet above £38m. The compliance notification is due by 5 December 2027, then the action plan by 5 December 2028.

What changed in July 2026

The ESOS (Amendment) Regulations 2026 came into force on 22 July 2026. Display Energy Certificates and Green Deal Assessments are gone as compliance routes. An ISO 50001 certificate covering 95% or more of your energy removes the need for an ESOS report and a Lead Assessor altogether. Everyone else needs a Lead Assessor audit covering 95% of consumption, plus a new action plan review that lists each measure implemented since Phase 3 with its estimated kWh saving. Net zero assessments remain voluntary.

Lead Assessor availability tightens in the last six months of every phase. Booking in 2026 for a 2027 audit is the cheapest decision on this list.

SECR and climate-related financial disclosures - unchanged and read more closely

Status. Mandatory. No change for FY2026 or FY2027 reporting.

SECR still applies to quoted companies and to unquoted companies and LLPs meeting two of three tests, 250 employees, £36m turnover, £18m balance sheet. Those figures did not move when the company size thresholds rose in April 2025, so a company that is now "medium" for its accounts can still be in SECR scope. The government's post-implementation review, published 26 May 2026, recommended keeping SECR with targeted amendments and a standard template. A consultation is promised but not dated.

The Companies Act climate-related financial disclosures (CFD) still apply from 500 employees for traded, banking, insurance and AIM companies. For everyone else the test is 500 employees plus £500m turnover. The government confirmed in February that a UK SRS S2 report satisfies the CFD requirement, so nobody reports twice. A review of CFD concludes in spring 2027.

What has changed is scrutiny. Auditors and investors now test methodology, boundaries and restatements against the source data. A footprint you cannot trace back to invoices and meter readings is the finding to avoid.

UK CBAM - the tax starts on 1 January 2027

Status. Mandatory. Primary legislation in Finance Act 2026, regulations made 13 July 2026.

If you import aluminium, cement, fertiliser, hydrogen, iron or steel goods worth £50,000 or more in any rolling 12 months, you are a CBAM taxpayer from 1 January 2027. The charge is the embedded emissions of the goods multiplied by a rate set from the mean UK ETS auction price of the preceding quarter, less any carbon price already paid overseas.

The compliance dates are back-loaded. Registration for 2027 liability is due by 31 January 2028. The first return and payment, covering all of 2027, are due 31 May 2028. Returns then go quarterly. Records must be kept for six years.

The data problem starts now. Your suppliers need to give you verified embedded emissions per product, or you pay on default values. If your reporting team has never spoken to your procurement team, this is the regime that introduces them.

Exporters into the EU face the mirror image. EU CBAM entered its definitive period on 1 January 2026. Your EU customers buy certificates from 1 February 2027 and file their first annual declaration by 30 September 2027, so they will ask you for emissions data before then.

CSRD after Omnibus I - check Article 40a, then stop or continue

Status. Mandatory (EU). Omnibus I in force 18 March 2026. Member states transpose by 19 March 2027.

For a UK parent, the test is Article 40a. You are in scope if EU net turnover exceeded €450m in each of the last two financial years and you have an EU subsidiary or branch with net turnover above €200m. There is no headcount test. EFRAG estimates the non-EU population fell from around 10,000 groups to around 1,200, of which 150 to 200 are British.

If you pass the test, your first reporting year is FY2028, reported in 2029, against a third-country standard EFRAG is consulting on until 31 October 2026. If you fail it, stop the group programme. We have been closing down CSRD projects that no longer need to exist and redirecting the budget for clients.

Your EU subsidiaries are a separate question. A subsidiary with more than 1,000 employees and €450m turnover reports on FY2027 in 2028, using the simplified ESRS the Commission adopted on 3 July 2026 with mandatory datapoints cut by more than 60%. A wave 1 subsidiary now below the thresholds exits from FY2027. Its FY2026 report depends on whether its member state has used the option to exempt it. As at August 2026, Germany, France, the Netherlands and Ireland had not legislated.

SBTi Corporate Net-Zero Standard V2.0 - 1 February 2027

Status. Voluntary. Final standard published 11 June 2026.

V2.0 takes effect on 1 February 2027. You can still submit under the current standard, V1.3.1, until 31 January 2028. From 1 February 2028 every new submission uses V2.0.

The changes are structural. Scope 1 and Scope 2 get separate targets and Scope 2 is measured on location-based emissions. Scope 3 targets must cover every category that is 5% or more of your Scope 3 total, replacing the old 67% coverage rule. Companies with turnover of €450m or 1,000 employees, Category A in the standard, must disclose a transition plan and obtain limited assurance over base-year data.

The decision is a sequencing one. If your target is close to submission, file under V1.3.1 before 31 January 2028 and plan the V2.0 transition at your next five-year review. If you are more than a year away, model against V2.0 now. Re-baselining after validation costs more than getting the boundary right first time.

Public sector buyers - PPN 026 and the NHS 2027 standard

Status. Mandatory for suppliers who want the contracts.

Central government's new Social Value Model, PPN 026, was published on 5 August 2026 and applies to procurements commenced on or after 1 January 2027 with a value of £1m or more. It narrows social value to two outcomes, jobs and skills, as our guide to what PPN 026 is and how it scores bids sets out in full. The climate theme is gone from the model. Carbon does not disappear from tenders. It moves to PPN 006, which requires a board-signed Carbon Reduction Plan, updated annually, for contracts above £5m a year. An expired plan remains the most common reason a bid fails the gate.

The NHS goes further. From 1 April 2027, contracts of £5m a year and every new framework, regardless of value, require the 2027 NHS Carbon Reduction Plan. That means global Scope 1, 2 and all relevant Scope 3 emissions, a net zero target of 2050 or earlier, board approval, publication on your website and an annual update. Contracts below £5m stay on the 2024 standard. NHS Supply Chain has required Evergreen Level 1 at tender close since 6 April 2026 and Level 2 aligns to the 2027 requirements.

Fund managers - SDR now, SFDR 2.0 later

Status. SDR mandatory. SFDR 2.0 proposed.

UK asset managers with £5bn to £50bn under management file their first entity-level SDR sustainability reports by 2 December 2026. In the EU, the Commission's SFDR 2.0 proposal of 20 November 2025 replaces Articles 8 and 9 with three product categories, Sustainable, Transition and ESG Basics, each with a 70% minimum. The Council agreed its position on 24 June 2026, with the European Parliament vote to follow. Application is 2028 at the earliest.

How to ensure ESG compliance in 2026/27

Four checks cover most of this list.

1. Run the Article 40a test. If you fail it, stop the CSRD programme.
2. Diarise 5 December 2026 for the ESOS progress update and book a Lead Assessor for Phase 4 now.
3. Gap-assess your last annual report against UK SRS S2 and map 1 January 2027 to your year end.
4. If you import CBAM goods, ask your suppliers for embedded emissions data before the year end.

Each of these is a scoping conversation, not a project. If you want a second opinion on any of them, speak to a consultant.

Sources

• UK SRS S1 and S2, Department for Business and Trade, 25 February 2026
• FCA CP26/5, Aligning listed issuers' sustainability disclosures with international standards, 30 January 2026
• Modernising Corporate Reporting consultation, 7 September 2026
• ESOS Phase 4 guidance, 30 July 2026
• The Energy Savings Opportunity Scheme (Amendment) Regulations 2026
• 2026 post-implementation review of the SECR Regulations 2018, 26 May 2026
• UK CBAM policy summary, HMRC, 16 July 2026
• Directive (EU) 2026/470, Omnibus I, Official Journal 26 February 2026
• Commission adopts revised ESRS, 3 July 2026
• SBTi Corporate Net-Zero Standard Version 2.0, June 2026
• PPN 026, The Social Value Model, 5 August 2026
• PPN 006, Carbon Reduction Plans in major government contracts
• 2027 NHS Carbon Reduction Plan requirements, NHS England, 9 June 2026
• CDP disclosure 2026 timeline