Sustainable Finance: key development timeline

Grania Baird

Jessica Reed

Kya Fear

Fiona Lowrie

As the EU and UK sustainable finance regulatory landscapes develop at pace, please see below a useful timeline which sets out the key developments we can expect in 2022.

For the background to the development of sustainable finance in the UK, please see our UK Guide, and for the background to the development of sustainable finance, please see our EU Guide.

UK Timeline
  • The window for application to take part in the FCA’s Green Fintech Challenge closed on 6 December 2021

    6 December 2021

  • The PRA expects firms to have fully embedded its Supervisory Statement 3/19

    31 December 2021

  • GTAG UK advice on green taxonomy and screening criteria expected. In effect, this has been delayed to 2022

    Q4 2021

  • Reference period for firms affected by Phase 1 of the implementation of the Environmental, Social and Governance (ESG) Sourcebook expected to take effect. First disclosures are to be published by 30 June 2023

    1 January 2022

  • Comments and feedback on DP21/4 were to have been received by the FCA

    7 January 2022

  • HMT FS Future Regulatory Framework Review consultation closed

    9 February 2022

  • Digital Sustainability Sandbox due to finish, outcomes to be published in due course

    March 2022

  • UK Government expected to consult on UK Green Taxonomy

    Q1 2022

  • The Climate Financial Risk Forum (CFRF) expects to launch an online climate scenario analysis narrative tool to support smaller firms

    Q1 2022

  • The Bank of England expects to publish the Climate Biennial Exploratory Scenario exercise results in May 2022

    May 2022

  • The FCA intends to consult in Q2 2022 on the proposed rules to implement SDR disclosure requirements as set out in DP21/4

    Q2 2022

  • The FCA intends to begin consulting on developing its policy approach to ESG governance, remuneration, incentives and training in regulated firms

    Q2 2022

  • The FCA is due to publish its first TCFD-aligned disclosure report in summer 2022

    Summer 2022

  • The government plans on updating its Green Finance Strategy, including setting out a pathway to align the financial system with the UK’s net zero commitment

    During 2022

  • The government intends to consult further on bringing ESG data and ratings providers within the scope of FCA authorisation and regulation

    During 2022

  • The government intends to legislate on climate change mitigation and climate change adaptation criteria under the UK green taxonomy

    End of 2022

  • The Transition Plan Taskforce is due to report on developing a standard for transition plans

    End of 2022

EU Timeline
  • The Commission is due to adopt technical screening criteria for remaining environmental objectives under Taxonomy Regulation. However, this has been delayed under 2022

    31 December 2021

  • Taxonomy Regulation - European Commission to publish a report about the provisions required for extending the scope of the Taxonomy Regulation beyond environmentally sustainable economic activities. However, this has been delayed under 2022

    31 December 2021

  • Periodic disclosure obligations under Article 11 of the SFDR (as it relates to Article 8 and 9 products) start to apply

    1 January 2022

  • ESMA published its Sustainable Finance Roadmap for 2022-24 which identified its upcoming priorities for this area

    11 February 2022

  • The EU Platform on Sustainable Finance published its final report on social taxonomy

    28 February 2022

  • The ESAs published an updated supervisory statement on the application of SFDR, to try to reduce the risk of a divergent application of SFDR and articles 5 and 6 of the Taxonomy Regulation

    24 March 2022

  • The Commission published a targeted consultation regarding the functioning of ESG ratings market and sustainability factors in credit ratings

    4 April 2022

  • The Commission adopted a delegated regulation supplementing SFDR with respect to the RTS specifying

    6 April 2022

  • The Commission is due to publish a report on the application of the Taxonomy Regulation by 13 July 2022

    13 July 2022

  • Level 2 amendments to UCITS directive AIFMD, MIFID, Solvency II and IDD to integrate sustainability factors begin to apply

    August 2022

  • On an annual basis from 10 September 2022, the ESAs will have to report to the Commission on best practices relating to the transparency of adverse sustainability impacts, and the implications of due diligence practices on disclosures under the SFDR

    10 September 2022

  • The Commission is expected to publish a report on the potential financial risks associated with biodiversity loss and ecosystem degradation

    During 2022

  • The Commission will consider energy-efficient mortgages as part of its review of the Mortgage Credit Directive

    During 2022

  • The Commission is due to evaluate the application of the SFDR

    30 December 2022

  • SFDR – product level disclosures on principal adverse impacts begin to apply

    30 December 2022

  • The Commission is expected to publish a report on social taxonomy under the Taxonomy Regulation

    31 December 2022

  • SFDR RTS – delayed applications of the content, methodologies, and presentation of sustainability-related disclosures due to apply

    1 January 2023

  • Disclosure requirements in the Taxonomy Regulation relating to remaining environmental objectives start to apply

    1 January 2023

UK Timeline
  • The window for application to take part in the FCA’s Green Fintech Challenge closed on 6 December 2021

    6 December 2021

  • The PRA expects firms to have fully embedded its Supervisory Statement 3/19

    31 December 2021

  • GTAG UK advice on green taxonomy and screening criteria expected. In effect, this has been delayed to 2022

    Q4 2021

  • Reference period for firms affected by Phase 1 of the implementation of the Environmental, Social and Governance (ESG) Sourcebook expected to take effect. First disclosures are to be published by 30 June 2023

    1 January 2022

  • Comments and feedback on DP21/4 were to have been received by the FCA

    7 January 2022

  • HMT FS Future Regulatory Framework Review consultation closed

    9 February 2022

  • Digital Sustainability Sandbox due to finish, outcomes to be published in due course

    March 2022

  • UK Government expected to consult on UK Green Taxonomy

    Q1 2022

  • The Climate Financial Risk Forum (CFRF) expects to launch an online climate scenario analysis narrative tool to support smaller firms

    Q1 2022

  • The Bank of England expects to publish the Climate Biennial Exploratory Scenario exercise results in May 2022

    May 2022

  • The FCA intends to consult in Q2 2022 on the proposed rules to implement SDR disclosure requirements as set out in DP21/4

    Q2 2022

  • The FCA intends to begin consulting on developing its policy approach to ESG governance, remuneration, incentives and training in regulated firms

    Q2 2022

  • The FCA is due to publish its first TCFD-aligned disclosure report in summer 2022

    Summer 2022

  • The government plans on updating its Green Finance Strategy, including setting out a pathway to align the financial system with the UK’s net zero commitment

    During 2022

  • The government intends to consult further on bringing ESG data and ratings providers within the scope of FCA authorisation and regulation

    During 2022

  • The government intends to legislate on climate change mitigation and climate change adaptation criteria under the UK green taxonomy

    End of 2022

  • The Transition Plan Taskforce is due to report on developing a standard for transition plans

    End of 2022

EU Timeline
  • The Commission is due to adopt technical screening criteria for remaining environmental objectives under Taxonomy Regulation. However, this has been delayed under 2022

    31 December 2021

  • Taxonomy Regulation - European Commission to publish a report about the provisions required for extending the scope of the Taxonomy Regulation beyond environmentally sustainable economic activities. However, this has been delayed under 2022

    31 December 2021

  • Periodic disclosure obligations under Article 11 of the SFDR (as it relates to Article 8 and 9 products) start to apply

    1 January 2022

  • ESMA published its Sustainable Finance Roadmap for 2022-24 which identified its upcoming priorities for this area

    11 February 2022

  • The EU Platform on Sustainable Finance published its final report on social taxonomy

    28 February 2022

  • The ESAs published an updated supervisory statement on the application of SFDR, to try to reduce the risk of a divergent application of SFDR and articles 5 and 6 of the Taxonomy Regulation

    24 March 2022

  • The Commission published a targeted consultation regarding the functioning of ESG ratings market and sustainability factors in credit ratings

    4 April 2022

  • The Commission adopted a delegated regulation supplementing SFDR with respect to the RTS specifying

    6 April 2022

  • The Commission is due to publish a report on the application of the Taxonomy Regulation by 13 July 2022

    13 July 2022

  • Level 2 amendments to UCITS directive AIFMD, MIFID, Solvency II and IDD to integrate sustainability factors begin to apply

    August 2022

  • On an annual basis from 10 September 2022, the ESAs will have to report to the Commission on best practices relating to the transparency of adverse sustainability impacts, and the implications of due diligence practices on disclosures under the SFDR

    10 September 2022

  • The Commission is expected to publish a report on the potential financial risks associated with biodiversity loss and ecosystem degradation

    During 2022

  • The Commission will consider energy-efficient mortgages as part of its review of the Mortgage Credit Directive

    During 2022

  • The Commission is due to evaluate the application of the SFDR

    30 December 2022

  • SFDR – product level disclosures on principal adverse impacts begin to apply

    30 December 2022

  • The Commission is expected to publish a report on social taxonomy under the Taxonomy Regulation

    31 December 2022

  • SFDR RTS – delayed applications of the content, methodologies, and presentation of sustainability-related disclosures due to apply

    1 January 2023

  • Disclosure requirements in the Taxonomy Regulation relating to remaining environmental objectives start to apply

    1 January 2023

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