ESG Reporting Timeline
Global ESG and sustainability reporting deadlines for private markets, covering mandatory and voluntary regimes across the US, UK, EU, and Australia. Half of what follows is not settled. The left rail tells you which half.
Little moved on the calendar, and that is the point. The November 10 double still anchors the window: the first SB 253 Scope 1 and 2 report and the entry into force of the revised ESRS land the same day. CDP’s final close is now inside the 60-day frame. In the US, the SEC closed its Climate Action 100plus probe on October 7 with no action but a warning that coordinated engagement can create a Section 13(d) group. The Ninth Circuit still has not ruled in Sanchez, so SB 261 stays paused while SB 253 runs on schedule.
Reading the left rail
- Final
- Fixed in law, regulation, or published rules. Plan against it.
- Likely
- Announced by the body, not yet legally effective.
- Proposed
- In consultation or trilogue. Could move.
- Watch
- No date. Could land any week in this window.
October 2026
2 entries- Week of Oct 26Final
CDP final close
The questionnaire closes. No further edits after this.
- Voluntary
- CDP
- Portfolio cos
- OctoberLikely
ISSB nature exposure draft at CBD COP17
ISSB is targeting an Exposure Draft of nature-related disclosure requirements for COP17. TNFD beginning to fold into the ISSB baseline.
- Voluntary
- ISSB / TNFD
- GPs · LPs
November 2026
2 entries- Nov 10FinalMoved
California SB 253, first Scope 1 and 2 report
The one portfolio companies will feel. CARB’s regulation cleared the Office of Administrative Law, so the date is firm. Applies to entities doing business in California with more than $1 billion in revenue, private companies included. CARB has signaled first-year enforcement discretion for good-faith filers.
- Mandatory
- Moved from Aug 10
- California
- Portfolio cos
- Nov 10Final
Revised ESRS enter into force
The delegated regulation carrying the revised ESRS enters into force the same day as the first SB 253 report. It applies to financial years from January 1, 2027, with early application allowed for 2026, and cuts mandatory datapoints by 61 percent against the 2023 standards.
- Mandatory
- EU
- Portfolio cos
December 2026
1 entry- Dec 30Final
EUDR enforcement, large and medium operators
Trilogue concluded and the revision is published as Regulation (EU) 2025/2650, so the enforcement date is now settled. Small and micro operators follow on June 30, 2027.
- Mandatory
- EU
- Portfolio cos
January 2027
6 entries- Jan 1Final
CSRD revised scope applies
For financial years beginning on or after this date. Scope narrows to EU entities over 1,000 employees and net turnover above €450 million. First reports land in 2028.
- Mandatory
- EU / CSRD
- Portfolio cos
- Jan 1Final
UK CBAM starts
Applies to importers of carbon-intensive goods into the UK.
- Mandatory
- UK
- Portfolio cos
- Jan 1Final
GRI 102 Climate Change and GRI 103 Energy take effect
New requirements on transition plans, just transition social aspects, and carbon credits. GRI 103 tightens energy disclosure and aligns with ISSB.
- Voluntary
- GRI
- Portfolio cos
- Jan 1Likely
New ESRS apply
Possibly with early application for financial years beginning on or after January 1, 2026.
- Mandatory
- EU / CSRD
- Portfolio cos
- Jan 1Likely
SB 253 Scope 3 begins
The within-year deadline is not set.
- Mandatory
- California
- Portfolio cos
- Jan 1Likely
UK SRS S2 mandatory for listed companies
The FCA finalized the UK SRS on September 30, 2026 on a comply-or-explain basis, for accounting periods starting on or after January 1, 2027. First reports in 2028, Scope 3 comply-or-explain from 2028. The broader expansion the FCA had floated was dropped.
- Mandatory
- UK
- Portfolio cos
Running through the window
- Likely · Voluntary · Jan–Feb 2027
SBTi Corporate Net-Zero Standard V2.0
V2.0 takes effect around January 31 or February 1, 2027 and validation opens. One source says legacy commitments must register by January 31, 2027, while SBTi’s own materials keep V1.3.1 available until January 31, 2028. Confirm with SBTi.
- Likely · Voluntary · Q1 2027
First ILPA Performance Template deliveries
Inception-to-date through March 31, 2027. The updated Reporting Template already took effect in Q1 2026. Voluntary, though LPs increasingly treat it as table stakes.
- Proposed · Mandatory · March 2027
EU Member States transpose Omnibus I for CSRD
National transposition of the CSRD scope changes, expected around March 2027.
- Final · Mandatory · Australia
AASB S2 Group 2
The first mandatory reporting period opened July 1, 2026. Thresholds are two of three: revenue over AUD 200 million, gross assets over AUD 500 million, or 250-plus employees. Nothing is due inside this window, but the clock started.
- Likely · Voluntary · Q3 2026
TNFD guidance pause
Current technical guidance wraps by Q3 2026, after which TNFD pauses new guidance to support ISSB standardization.
- Likely · Voluntary · Q4 2026
SBTi Q4 deliverables
Final methods and pathways, a Renewal Policy, and the first instrument recognitions under the Ongoing Emissions Responsibility program.
- Likely · Voluntary · H2 2026
GRI labor standards
GSSB approval of eight revised labor Topic Standards.
- Watch · United States
Ninth Circuit ruling, Chamber of Commerce v. Sanchez
Argued January 9, 2026. No decision, no timeline. The SB 261 injunction holds until it rules, and CARB has made SB 261 voluntary meanwhile. More than 170 companies filed climate risk reports to the docket anyway as of June 26. A ruling reshapes two entries above.
- Watch · European Union
SFDR 2.0 trilogues
Article 8/9 would give way to Transition, ESG Basics, and Sustainable. Existing SFDR obligations stay fully applicable throughout. Application is 18 months after entry into force, so late 2027 or 2028.
Just past the window
- April 30, 2027 EDCI submission. Collection runs through the fall.
- June 30, 2027 SFDR PAI statements, covering calendar 2026.
Re-checked every issue
Six things can flip any week. Each one moves an entry between statuses, or deletes it.
- Ninth Circuit ruling in Chamber of Commerce v. Sanchez, which unblocks or kills SB 261
- SEC treatment of coordinated engagement as a Section 13(d) group, after the CA100plus probe closed with a warning
- SFDR 2.0 trilogue, and how funds get relabeled
- SB 253 Scope 3, with the within-year deadline still unset
- ISSB nature exposure draft, and the pace of TNFD folding into the ISSB baseline
This timeline covers a rolling window from the issue date and is updated every other week. Dates marked Proposed or Watch are not commitments and should not be planned against without checking the source.