A Daily Network publication
Explore the network
ESG Capital Daily
Independent Intelligence on Sustainable Investment Capital
Wednesday, October 14, 2026The Morning Brief →Sign in
Policy & Disclosure

ESMA issues greenwashing guidance on impact and transition claims

The thematic note creates no new obligations but asks fund and bond providers to distinguish investor impact from investee impact.

At a glance

25-second brief
  • ESMA announced a thematic note on 14 October covering how fund and bond providers should address greenwashing risk in positive impact and climate transition claims.

  • On positive impact claims, ESMA said observed practices showed confusion between investor and investee impact and claims lacking sufficient substantiation.

  • The four-part test is now applied explicitly to impact and transition claims, two categories the regulator says it observed being made without adequate rationale or substantiation.

ESMA announced a thematic note on 14 October covering how fund and bond providers should address greenwashing risk in positive impact and climate transition claims. The note is meant to support market participants' understanding of expectations for communication that is clear, fair and not misleading, ESG Today reported.

It is the latest in a series ESMA began in July 2025 with guidance on references to ESG credentials such as qualifications, labels, ratings and certificates, followed in early 2026 by a note on ESG integration and ESG exclusion funds. Each note in the series applies four principles: claims must be Accurate, Accessible, Substantiated and Up to Date.

Investor impact versus investee impact

On positive impact claims, ESMA said observed practices showed confusion between investor and investee impact and claims lacking sufficient substantiation. The note also cites claims made without a clear rationale for how the investment strategy is expected to contribute to positive impact, and it observes that market participants understand positive environmental or social impact differently and attach different levels of ambition to their impact claims.

ESMA encouraged providers to explain clearly what difference they expect to make and how they aim to generate positive impact. It pointed to intentionality, meaning an explicit aim to generate positive impact, and to additionality. Failure to distinguish clearly between investee impact and investor impact may result in misleading claims, the note says. Providers are also encouraged to explain how they will measure results through KPIs focused on outputs, outcomes or impact.

For climate transition claims, ESMA noted they are typically forward-looking, describing the gradual improvement of the climate performance of companies, assets or activities rather than current environmental characteristics. That creates inherent uncertainty and potential requirements for future adjustments, the regulator said, because the claims rely on assumptions and on external factors that evolve over time, such as technological progress and public policy developments. ESMA highlighted the need for clear communication on the transition ambit.

Guidance with no deadline attached

The note carries no new filing requirement and no compliance date. Its practical weight sits against the supervisory machinery around it: as this publication has reported, ESMA does not begin supervising ESG rating providers until 2027, and the EU's green-claims penalty regime took effect before a verification infrastructure existed.

The four-part test is now applied explicitly to impact and transition claims, two categories the regulator says it observed being made without adequate rationale or substantiation.

Continue your research

Save this analysis and keep the funds you follow together in My Desk.

Sign in to save articles or follow funds.
Sources & further reading
ESG Today
In this storyESMA
More from ESG Capital Daily
Policy & Disclosure

EFRAG names Kristian Koktvedgaard acting chair of its sustainability reporting board

Koktvedgaard has served on the board since it was established and remains acting chair until the General Assembly appoints a permanent successor.
Policy & Disclosure

South Korea's $747 billion K-GX plan links climate finance to emissions cuts

The 2035 strategy pairs about $149 billion in fiscal spending with more than $590 billion in climate finance and counts on $164 billion more from private investors.
The Wrap

Ircantec awards Amundi and BNP Paribas nearly €1.6bn climate-linked equity mandates

The mandate uses a custom MSCI SRI index with a 7% annual decarbonization target.
Elsewhere in the networkAll titles →
Every weekday · 6:30 a.m. ET

The Morning Brief

The latest from ESG Capital Daily, in your inbox every weekday. Free.