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Sustainability reporting standards, worldwide

Which climate and sustainability disclosure rules reach your company, what they ask for, and when. Covers the United States, the European Union, the United Kingdom and the jurisdictions adopting ISSB standards. Every date links to its source.

Check which apply to you →California SB 253
Checked 6 October 2026Primary sourcesUpdated as regulators act
2026 in four numbers

The year the rules split

Washington stepped back and Sacramento stepped forward. Brussels cut its regime to the largest companies. London published its own version of the global baseline and asked listed companies to adopt it.

For a multinational, that means several overlapping regimes at different stages, not one rulebook. The finder below sorts out which are worth your attention.

2,596Companies CARB's preliminary list flagged as potentially in scope of SB 253CARB list, via Harvard Law Forum[1]
45+Jurisdictions adopting or taking steps towards ISSB standardsIFRS Foundation, Sep 2026[2]
1,000+Employees before an EU company is in CSRD scope after Omnibus ICouncil of the EU[3]
61%Cut in mandatory ESRS datapoints in EFRAG's simplified standardsEFRAG[4]
Your answer

Which regimes reach you?

Five questions, answered in the order a reporting team would ask them. The result is a starting list: what is likely to apply, what to check, and what you can watch for now.

Thresholds are summarised. Each regime’s page has the detail and the primary text.

Where is your company organised?
Does the group do business in California?
Group revenue, worldwide
More than €450m turnover in the EU?
Shares listed in London?

Answer the first question to see which regimes are worth your attention.

The four regimes

Start here

United States

SB 253, SB 261 and the SEC

California's emissions and climate-risk laws, and the federal rule that never took effect.

First deadline 10 Nov 2026*
Read →Global baseline

ISSB: IFRS S1 and S2

The standard most of the world is adopting, country by country.

Over 45 jurisdictions
Read →European Union

CSRD and ESRS

Narrowed by Omnibus I, with simplified ESRS from 2027.

Law, narrowed
Read →United Kingdom

UK SRS S1 and S2

Published and voluntary, with FCA rules for listed companies proposed.

Voluntary → proposed
Read →

*Subject to approval of CARB’s regulation.[7]

Timeline

What happened, and what comes next

Every milestone across the four regimes in one sequence. Filter by jurisdiction, or show only what is still to come.

Dates marked “not yet final” depend on a regulator acting. We update them when it does.

  1. 26 Jun 2023ISSB
    ISSB issues IFRS S1 and IFRS S2
  2. 6 Mar 2024US
    SEC adopts its climate disclosure rule, then stays it on 4 April
  3. 27 Mar 2025US
    SEC votes to stop defending the rule in court
  4. 16 Apr 2025EU
    Stop-the-clock directive delays CSRD waves 2 and 3 by two years
  5. 18 Nov 2025US
    Ninth Circuit enjoins California SB 261 pending appeal
  6. 11 Dec 2025ISSB
    ISSB issues targeted amendments to IFRS S2
  7. 30 Jan 2026UK
    FCA consults on UK SRS-based rules for listed companies (CP26/5)
  8. 25 Feb 2026UK
    UK SRS S1 and S2 published for voluntary use
  9. 26 Feb 2026EU
    Omnibus I (Directive 2026/470) published: CSRD narrowed to 1,000+ employees and €450m+ turnover
  10. 29 May 2026US
    SEC proposes rescinding the climate rule in full
  11. 21 Sep 2026EU
    Simplified ESRS published as Delegated Regulation 2026/1563
  12. Autumn 2026UKNot yet final
    FCA aims to publish its policy statement on listed-company rules
  13. 10 Nov 2026USNot yet final
    First SB 253 Scope 1 and 2 reports due, if CARB's regulation is approved
  14. 10 Nov 2026EU
    Simplified ESRS enter into force
  15. 1 Jan 2027EU
    Simplified ESRS apply to financial years starting on or after this date
  16. 1 Jan 2027ISSB
    IFRS S2 amendments take effect
  17. 1 Jan 2027UKNot yet final
    FCA's proposed rules would apply to periods starting on or after this date
  18. 2027US
    SB 253 Scope 3 reporting begins, on a schedule CARB sets
  19. 1 Jul 2027EU
    Deadline for the Commission to adopt limited-assurance standards
  20. 2030US
    SB 253: reasonable assurance on Scope 1 and 2, limited assurance on Scope 3
Side by side

One baseline, four rulebooks

ISSB is the common root. The EU went further with double materiality, the UK adapted ISSB lightly, and California wrote its own emissions law. Pick a column to compare it with the rest.[8],[9],[12],[6]

TopicISSB (IFRS S1/S2)EU ESRSUK SRSCalifornia SB 253
Issued byInternational Sustainability Standards BoardEuropean Commission, on EFRAG's adviceUK Secretary of State for Business and TradeCalifornia legislature; CARB writes the rules
Legal forceNone on its own; applies where a jurisdiction adopts itLaw: Delegated Regulation (EU) 2026/1563Voluntary; FCA has proposed rules for listed companiesStatute in force; CARB's first regulation awaits approval
Who reportsSet by each adopting jurisdictionEU companies over 1,000 employees and €450m turnover; some non-EU groupsAnyone who chooses to; listed companies if FCA rules are madeUS entities over $1bn revenue doing business in California
MaterialityFinancial: what matters to investorsDouble: financial and impactFinancial, as ISSBNot applicable: an emissions inventory
Scope 3Required, with first-year reliefRequired where materialRequired, with a relief whose end date regulators will setFrom 2027, on a schedule CARB sets
First reportsPeriods from 1 Jan 2024, where adoptedSimplified ESRS: financial years from 1 Jan 2027None mandatory; FCA proposes periods from 1 Jan 202710 Nov 2026 proposed, Scope 1 and 2
Questions

Asked often

What are sustainability reporting standards?

They set out what a company discloses about sustainability and climate risks, its greenhouse gas emissions and, in Europe, its impacts on people and the environment. The global baseline is the ISSB’s IFRS S1 and S2. The EU uses ESRS, the UK has UK SRS, and California has its own emissions and climate-risk laws.

Is there a US federal sustainability reporting requirement?

No. The SEC adopted a climate disclosure rule in March 2024, stayed it, and never brought it into effect. On 29 May 2026 it proposed rescinding it.[5] The live US requirements are state laws, chiefly California’s SB 253 and SB 261. US rules in full →

When is the first California SB 253 report due?

CARB has proposed 10 November 2026 for the first Scope 1 and 2 reports, covering the prior fiscal year. The date depends on California’s Office of Administrative Law approving CARB’s regulation.[7]

Who has to report under the EU CSRD now?

After Omnibus I, EU companies with more than 1,000 employees and more than €450m net turnover, plus non-EU groups with more than €450m EU turnover and an EU subsidiary or branch above €200m.[3] CSRD and ESRS →

Is UK SRS mandatory?

Not yet. UK SRS S1 and S2 were published on 25 February 2026 for voluntary use.[12],[10] The FCA has proposed requiring listed companies to use them for periods starting on or after 1 January 2027.[11] UK SRS →

Sources

Where this comes from

Primary sources unless labelled secondary. Checked 6 October 2026.

  1. [1]CARB publishes preliminary list of companies potentially subject to SB 253 and SB 261Harvard Law School Forum on Corporate Governance (secondary, reporting CARB's list) · 12 October 2025
  2. [2]Adoption of IFRS Sustainability Disclosure Standards (World Standard-setters Conference plenary)IFRS Foundation · September 2026
  3. [3]Council signs off simplification of sustainability reporting and due diligence requirementsCouncil of the EU · 24 February 2026
  4. [4]European Commission adopts revised ESRS and voluntary sustainability reporting standardEFRAG · 22 September 2026
  5. [5]SEC proposes rescission of climate-related disclosure rules (Press release 2026-49)US Securities and Exchange Commission · 29 May 2026
  6. [6]California Health and Safety Code §38532 (SB 253, Climate Corporate Data Accountability Act)California Legislative Information · statute as amended by SB 219
  7. [7]Guidance for SB 253 2026 ReportingCalifornia Air Resources Board · September 2026
  8. [8]ISSB issues inaugural global sustainability disclosure standardsIFRS Foundation · 26 June 2023
  9. [9]Commission Delegated Regulation (EU) 2026/1563 (revised ESRS)Official Journal of the EU · 21 September 2026
  10. [10]UK Sustainability Reporting Standards (guidance)GOV.UK · last updated 25 February 2026
  11. [11]CP26/5: Aligning listed issuers' sustainability disclosures with international standardsFinancial Conduct Authority · 30 January 2026
  12. [12]UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2Department for Business and Trade, GOV.UK · 25 February 2026