ESG developments in 2025

Sustainability practitioners will be well aware that ESG is a fast-moving, and ever changing area, making keeping on top of developments a significant challenge. We have sought to set out key ESG developments expected in 2025, covering the UK and, at a high level, the EU, to support with horizon scanning efforts.

In this timeline and webpage, accurate as of January 2025, we outline some of the key dates to look out for. Although many dates are provisional, the timeline will be updated on a quarterly basis to keep you informed of future developments. The below drop-down boxes on this webpage contain a list of additional developments that are expected to occur at some point during 2025, and for which we do not yet have a set date. Throughout the year, we will also continue to publish timely updates through our Sustainable Matters blog and Horizon Scanning programme of short articles and podcast episodes. Please refer to the timeline for a list of definitions.

Environmental

The Water (Special Measures) Bill 2024-25 will continue its passage through Parliament. The Bill strengthens the powers of the water regulator and environment regulators.

Legislation for producer responsibility for waste electrical and electronic equipment (WEEE) is expected to be introduced to: (i) align the obligations of online marketplaces with those of conventional producers, and (ii) introduce a new category of WEEE for producers to report vapes.

The Circular Economy Taskforce is expected to publish a strategy for England. The Taskforce is expected to publish the Strategy between Summer and Autumn 2025.

The UK government is expected to publish a roadmap for the delivery of new Environmental Outcome Reports, as part of proposed reforms to environmental impact assessments.

A revised Environmental Improvement Plan is expected to be published, following the UK Government's 'rapid review', which will set out plans to protect and restore England's natural environment, including plans to meet the Environment Act 2021 targets.

Several consenting regimes may be moved into the Environmental Permitting regime in 2025. These include waste carriers, brokers and dealers and water abstraction licensing.

The UK Government is expected to publish a response to the feedback received on its December 2023 consultation on Future Homes and Buildings Standards.

The UK Government is expected to consult on a ban of new North Sea oil and gas licences.

The UK CBAM is expected to complete its passage through Parliament. The Government is also expected to consult on and lay secondary legislation in relation to the UK CBAM. The UK Government intends for the UK CBAM to apply from January 2027.

Social

The Employment Rights Bill will continue to pass through Parliament, with a number of consultations on the proposed reforms expected. Please refer to our briefing for further information on the Employment Rights Bill.

Consultations expected in relation to the proposed Equality (Race and Disability) Bill.

The UK Government may launch additional consultations on legislative and non-legislative measures, and/or announce new measures, to tackle forced labour and transparency in supply chains, following its response to the House of Lords Committee Report on the Modern Slavery Act 2015 (MSA), and the Joint Committee on Human Rights’ announcement on 21 January 2025 of a new inquiry to examine the UK's legal and voluntary frameworks underpinning the UK's response to forced labour in international supply chains, whether they are effective, and whether changes are required. Updated section 54 MSA statutory guidance is also expected at some point this year. Please see our blog for more detail.

Governance and Reporting

The FCA is expected to consult on updating its TCFD-aligned disclosure rules to bring them in line with the UK SRS (subject to a positive UK Government endorsement decision). This may be combined with the FCA's consultation on transition plan disclosures. Any changes that are introduced are not expected to be effective for accounting periods beginning before 1 January 2026.

The UK government is expected to consult on introducing UK SRS disclosures for economically significant companies (subject to a positive UK Government endorsement decision). This could take place as early as Q2 2025. Any changes that are introduced would not be effective for accounting periods beginning before 1 January 2026. However, requirements are expected to apply later (likely from 2028).

The Department for Business and Trade is expected to launch a consultation on the Future of Corporate Reporting, aimed at simplifying the non-financial reporting framework.

Sustainable Finance

The FCA is to consult on, or consider, applying the SDR to financial advisors, pension products and other investment products marketed to retail investors, and listed issuers. HM Treasury is to consult on applying the SDR and labelling regime to funds operating under the overseas funds regime.

The FCA is expected to introduce new prospectus disclosure requirements for sustainability-labelled debt securities in 2025. The FCA aims to finalise rules for the public offers and admission to trading regime in late 2025.

1502887 What To Look Out For In ESG In 2025 Timeline JAN 2025 V3 1

Timeline of Anticipated ESG Developments in 2025 View timeline

Please note that this webpage is a summary and is necessarily not comprehensive. Please speak to your usual contact at Slaughter and May for more information on ESG horizon scanning, including information tailored to your business and/or sector.

This material is provided for general information only. It does not constitute legal or other professional advice.

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