The nucleation mechanism of recrystallisation of a cold rolled Ti-SULC steel was studied by Orientation Imaging Microscopy (OIM) in order to increase the fundamental understanding of the process and to generate a dataset for validation of a microstructural model. The annealing treatment was interrupted several times to capture different stages of the recrystallisation process. In addition, using a hot stage SEM, in-situ observations were made of the recrystallisation process. It appears that nucleation occurs by growth of subgrains or pre-existing nuclei, with little or no incubation (recovery) required. They have gamma-fibre orientations and form at the grain boundaries and near internal shear bands of {1 1 1} grains. Due to the orientation gradient present at these locations, the subgrains can form high angle grain boundaries (HAGBs), which allows them to grow quickly. The {0 0 1} grains recrystallise very late in the process due to a low stored energy. The preferred orientation of the recrystallised grains is thought to be related to the subgrain size distribution, where the particularly large subgrains are the ones that will grow.