On 12 October 2026, the European Securities and Markets Authority (ESMA) issued two additional thematic notes on sustainability-related claims. The additional notes cover impact claims and climate transition claims.
Background
The thematic notes do not create new regulatory requirements and should not be understood as prescribing a particular approach or level of ambition, for example in the context of the ongoing review of the Sustainable Finance Disclosure Regulation (SFDR). Instead, the notes provide observations and examples intended to support market participants’ understanding of the existing expectations under the principle of clear, fair and not misleading communication.
The thematic note on impact claims examines positive impact claims made through funds and bonds. The thematic note on climate transition claims draws on observed market practices across funds, bonds and benchmarks. The thematic notes offer practical do’s and don’ts for making sustainability claims in non-regulatory communications, illustrated through examples of good and poor practices that are based on observed market practices. They aim to ensure communications are clear, fair and not misleading and reduce the risk of greenwashing.
