ESMA publishes updated sustainable finance implementation timeline

October

• Third ESAs Report on voluntary disclosures under SFDR to be published

21 November

• ESG Fund Names Guidelines starts to apply for all newly created ESG funds

1 January

• Non-financial undertakings disclose KPIs on taxonomy-alignment under the TR Disclosures Level 2 RTS (additional activities & environmental objectives pursuant to TR Article 9)

Q1

• Undertakings previously subject to the Non-Financial Reporting Directive start reporting under ESRS Set 1: requirements apply to financial years (FYs) starting on / after 1 January 2024, first reporting 2025

21 May

• End of transition period for funds existing prior to the ESG Fund Names Guidelines application date

March to June

• EuGBR consultation on remaining technical standards

Mid-2025

• European Commission Review of SFDR Level 1 Review – note that this is now marked as tentative

End of 2025

• Transitional provisions end for third country benchmarks under the Benchmark Regulation

1 Jan

• Financial undertakings disclose KPIs on taxonomy-alignment under the TR Disclosures Level 2 RTS (additional activities & environmental objectives pursuant to TR Article 9)

Q1

• Large undertakings not previously subject to NFRD start reporting under ESRS Set 1: requirements apply to FYs starting on / after 1 January 2025, first reporting in 2026

21 June

• End of EuGBR Article 69/70 transition period

• Listed SMEs and small & non-complex FIs report under ESRS for LSMEs (optional): requirements apply to FYs starting on / after 1 January 2026, first reporting in 2027 (opt-out possible until 2029)

• Listed SMEs and small & non-complex FIs report under ESRS for LSMEs (mandatory)

• Third country undertakings report under third country ESRS: requirements apply to FYs starting on / after 1 January 2028, first reporting in 2029