Get Ready Before 2026 Ends
The past six months, the focus has mostly been about speculations about ESG threads and how big the Omnibus reductions would be. But things are now starting to be more clear. Some regulations that have been anticipated for almost two years are now finally set for quarters 3 and 4 of 2026. At the same time, some rules have been extended just enough to create a misleading perception of “we still have time.”
Take a quick, accurate look at what’s really shifting so you know what to do before the year ends.
As of July 2, 2026, the European Securities and Markets Authority (ESMA) is directly supervising ESG rating providers (MSCI, Sustainalytics, ISS, S&P and Bloomberg) for the first time under the EU ESG Ratings Regulation (2024/3005). For companies that rely on third-party ESG ratings for their investing or disclosure processes, July is the month where the situation evolves regarding those providers.
For the companies affected by SB 253/SB 261, the timeline has been pushed a few times by California Air Resources Boards (CARB) to announce that the final deadline is now November 10, 2026. With regard to SB 261’s climate-risk reporting deadline, it is still on pause and remains voluntary.
What’s mostly worrying about the companies is how they approach these delays as a good reason to not pay further attention until they are obliged to. But this waiting comes in contrast with what CARB suggests. Companies should make a fair attempt to concentrate whatever data there is available for year one as a minimum requirement. But the longer the delay in doing so, the more difficult it will be to start actions.
Is your company doing business in California and crossing the revenue thresholds as implied? These questions should not be answered at the end of the year, regardless of the upcoming Scope 1/2 deadline dates.
As far as CSRD is concerned, the situation is more straightforward. On March 18, 2026, Omnibus I was finalized as EU law requiring mandatory reporting for the companies in the EU that have more than 1,000 employees and €450 million net turnover. Then for the companies in WAVE 2, it is due in 2028 to publish their first reports, covering FY2027.
SFDR 2.0 is the regulation still under development. On June 24, 2026, the Council agreed on its negotiating position, but Parliament is expected to define its position no sooner than Q3. That means that the effect date will most likely be in 2028, since it is required to have an 18-month implementation period following the draft of the final text. The reform is also a bigger structural shift than people expect: it replaces the familiar Article 8/9 fund classifications with three new categories (Sustainable, Transition, and ESG Collection), turning SFDR from a disclosure regime into something closer to a product-labeling regime.
The ESG Ratings Regulation also has its first real deadline in August: large providers must notify ESMA by August 2, 2026 to keep operating in the EU, with small providers given until November 2—worth mentioning alongside SFDR since the revised framework will require asset managers to disclose whether the ratings they cite come from an authorized provider.
For the companies still in CSRD scope, this is an important month. On June 3, 2026, EFRAG concluded the simplification of ESRS after its final public feedback to cut 61–68% in mandatory datapoints. The European Commission is expected to adopt the revised standards via delegated act around mid-2026, with mandatory application from FY2027 but early adoption permitted for FY2026 for companies already reporting. That means that for the companies in WAVE 1, this is the period to decide whether they will decide to adopt the simplified standards a year sooner.
For every tonne of cement, steel, aluminum, fertilizer, hydrogen, or electricity that companies import into the EU, they are already generating certificate liability, even though the first actual certificate purchase doesn’t happen until February 2027, and the first annual declaration isn’t due until September 30, 2027.
This final phase of CBAM has been in effect since the beginning of 2025. However, companies should not translate the non-mandatory payment yet as an excuse to avoid taking action. Verifiers must conduct on-site inspections in 2026; default emission values are punitively high compared to verified actual values, and authorized-declarant applications were already due by March 31, 2026 for companies that wanted to keep importing without disruption. Budget conversations for 2027 certificate costs should be happening now, using 2026 import volumes.
The EU Deforestation Regulation has been delayed for the second time. Two different dates for compliance: 30 December 2026 is for large and medium operators, while small/micro operators should comply by 30 June 2027. The Commission completed its required simplification review by the April 30, 2026 deadline, and the regulation now focuses on fewer items (no printed materials), has easier one-time declarations for small primary producers, and shifts the responsibility for due diligence to the first operator bringing goods into the EU market. If cocoa, coffee, palm oil, soy, cattle, rubber, or wood products are part of a company’s supply chain, December 2026 is now the actual deadline. Although the timeline is questionable because each year since 2023 we have come across different meanings as to what is actual. It is suggested that companies should start working on backup plans and remain vigilant while waiting for the date.
With regard to the UK’s sustainability reporting framework, it is encouraging to see that it has become more solid. Companies can use The UK’S IFRS S1/S2-aligned standards voluntarily since their finalization in February. The Financial Conduct Authority will publish final listing rules and mandatory UK SRS S2 (climate) reporting for listed companies that will start in the beginning of 2027.
For multinational companies dealing with CSRD and ISSB-aligned frameworks, the UK SRS does not necessarily need to be treated as something separate. Instead, this year companies have the opportunity to integrate the data into the same blueprint they were used to.
2026 seems to surface a pattern for almost every one of these ESG threads. Whether to change scope and timelines or confirm deadlines, even if they are delayed, all of these ESG threads indicate some kind of movement.
California is reporting in November regardless of where SB 261 litigation lands. CBAM liability is accruing today even though payment is a year away. CSRD’s universe shrank by 80%, but the companies still inside it face simplified — not eliminated — requirements arriving as soon as next year’s reporting cycle. The work for the rest of 2026 isn’t waiting for certainty; it’s building systems flexible enough to absorb whatever the next delay or threshold change turns out to be. Get the right set of sustainability and ESG skills for your teams and get ready before 2026 ends.
