Greenwashing: Standardisation is crucial

On 16 January 2023, the comment period for the consultation of EU authorities on greenwashing expired.

A spokesperson for the German Investment Funds Association BVI said:

"We welcome the efforts of the ESAs to tackle greenwashing. However, in view of the many open questions on the interpretation of the EU regulation, the current focus on a broad market investigation into suspected cases is, in our view, too early. Reasonable approaches to implementing the EU requirements should in any case not be considered as greenwashing. To contain the risk of greenwashing, standardisation is the best approach. This includes the overdue clarification of essential concepts of the SFDR, especially the criteria for sustainable investments. In addition, EU legislators should oblige ESG rating providers to disclose their methods and data procurement processes. Fund companies would then be in a better position to assess the quality of ESG ratings."

You can find the BVI statement here.

A summary of the key statements of the BVI statement can be found here.


The three European Supervisory Authorities (ESAs) published a joint market sounding ("call for evidence") on greenwashing in November 2022. In doing so, the ESAs are exercising the mandate given to them by the EU Commission in May 2022 to conduct corresponding investigations. The ESAs are to document potential cases of greenwashing for the respective supervised sectors, report on appropriate supervisory measures and propose any adjustments to the EU regulatory framework. This is to be done initially in progress reports by the end of May 2023, then in final reports by the end of 2024.

The market sounding serves to document potential greenwashing needed for the progress report. Accordingly, the ESAs focus on the following topics:

  • What is meant by greenwashing, and what might be the main reasons for greenwashing.
  • Examples and evidence of potential greenwashing practices across the EU financial sector at the company and product levels.
  • Data to help ESAs gain a concrete picture of the extent of greenwashing in their respective jurisdictions and identify areas of high greenwashing risk.

Member area

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