ESMA thematic note on sustainability-related claims used in non-regulatory communications

Background

The European Securities and Markets Authority (ESMA) is launching a series of thematic notes as part of its work on greenwashing. Designed for educational purposes, these notes aim to clarify ESMA’s expectations regarding the formulation of sustainability claims, but do not introduce new regulatory or reporting requirements. The first note, published on 1 July 2025, focuses on ESG credentials.

Scope

The note is addressed to all stakeholders in the sustainable investment value chain, including issuers, asset managers, index administrators and investment service providers. It specifically targets non-regulatory communications (marketing materials, voluntary reports, online content, etc.). The focus is on references to ESG credentials, such as statements promoting labels, awards, external ratings, membership of industry initiatives and peer comparisons in the area of ESG.

Key principles

The note is built around four guiding principles to follow when framing communications on ESG-related matters. ESMA expects sustainability claims to be:

• Accurate: ESG claims must accurately reflect reality, without exaggeration or omission. Vague messages, cherry-picking or misleading use of ESG terms, visuals or symbols should be avoided.
• Accessible: sustainability claims must be based on easily accessible and readily available information, while providing sufficient detail. When space is limited — particularly in concise documents intended for retail investors — ESMA recommends a layered approach, allowing for additional explanations to be provided gradually via easy-to-find online content.
• Substantiated: sustainability claims must be based on credible facts, methods and processes. They must be supported by clear, relevant and proportionate methodologies, with mention of the limitations, underlying assumptions and comparison criteria used.
• Up to date: sustainability claims must be based on up-to-date information, with any significant changes communicated promptly. The date and scope of the analysis could be included to ensure transparency.

The thematic note then illustrates each of these principles through a series of practical examples and a structured list of best practices (“Do’s”) and things to avoid (“Don’ts”), enabling stakeholders to better frame their ESG communications.

Next steps

Further notes will follow, if deemed necessary, and should be read in conjunction with this document as part of a comprehensive thematic study.

Authors: Maya Perrier and Valérian de Jamblinne