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Regulatory briefing: greenwashing

October 2026

Greenwashing in a changing sustainability landscape

Greenwashing has evolved. While scrutiny once focused on broad environmental claims, regulators, investors, NGOs, and journalists are increasingly examining the credibility of energy transition strategies. Net-zero commitments, transition finance products, renewable energy investments, and climate leadership claims are now at the center of many greenwashing allegations.

This scrutiny is reflected in the wider business conduct risk landscape. A 2026 survey of C-suite executives found that the energy transition (#2) and greenwashing (#4) are among the top material risks companies expect to navigate over the next three years.

# Top material risks according to C-suite executives over the next 3 years

Question: Which of the following business conduct risks were / will be the most material for your company in each of the following time periods? Rank top 3. Source: Oxford Economics survey, January 2026.

RepRisk data reflects the growing scale of that scrutiny: greenwashing risk incidents increased 112% between 2022 and 2026, while 1,594 companies were linked to greenwashing in 2026, up 28% from the previous year.

This evolution has given rise to what is often described as transition-washing: the tendency to emphasize future climate ambitions, long-term transition plans, or selective low-carbon investments without demonstrating corresponding changes in present-day business activities.

# Why transition-washing matters

Historically1, greenwashing often involved vague or unsubstantiated environmental claims. Today, many of the most scrutinized claims relate to the energy transition, including net-zero targets, transition finance, renewable energy investments, carbon capture technologies, sustainable aviation fuels, and other decarbonization initiatives.

In 2026, ecosystems and biodiversity became the environmental issue most frequently linked to greenwashing risk in RepRisk data, overtaking climate change and emissions for the first time in five years. The finding underlines why credible transition strategies increasingly need to account for the wider environmental footprint of the activities they support.

As organizations compete to demonstrate climate leadership, the risk increasingly lies in the gap between stated ambitions and real-world performance. Greenwashing therefore often arises not through outright falsehoods, but through selective disclosure, optimistic framing, or incomplete representation of environmental and social impacts.

# How are regulators responding to greenwashing?

Regulators around the world are introducing new disclosure rules, claim substantiation requirements, and sustainability reporting frameworks designed to reduce misleading environmental claims. While the details vary by jurisdiction, most initiatives share a common objective: increasing transparency and accountability around sustainability-related communications.

# Notable regulations and frameworks addressing greenwashing

Global

Europe

North America 

Asia Pacific (APAC)

Middle East 

# What this means for risk, compliance, and sustainability managers

Increasingly, organizations need to understand whether sustainability or climate commitments are supported by evidence, implementation, and observable progress. Transition-related risks can emerge from changing stakeholder expectations, media scrutiny, NGO campaigns, litigation, regulatory developments, and allegations of greenwashing or transition-washing. As scrutiny around the energy transition continues to evolve, organizations need visibility into how their claims, strategies, investments, and business activities are perceived by external stakeholders.

RepRisk provides an outside-in perspective on business conduct risk, helping clients identify emerging issues related to climate commitments, transition plans, transition finance, environmental impacts, human rights concerns, regulatory compliance, and allegations of greenwashing or transition-washing. This can help organizations assess the credibility of transition strategies and complement traditional climate and financial risk assessments.

Want to learn more about how RepRisk solutions mitigate greenwashing risk?

Request a demo and a RepRisk specialist will contact you. 


[1] RepRisk has published a report centred around greenwashing for five consecutive years. You can find the 2022 – 2026 reports here: “Spotting greenwashing” (2022), “On the rise: navigating the wave of greenwashing and social washing” (2023), “A turning tide in greenwashing? Exploring the first decline in six years” (2024), “Where biodiversity risks grow greenwashing follows” (2025), and “How the energy transition became greenwashing’s next frontier” (2026). Please note that data from 2024 onward may not be directly comparable to previous years due to a methodological update.

Copyright 2026 RepRisk AG. All rights reserved. RepRisk AG owns all intellectual property rights to this report. This information herein is given in summary form and RepRisk AG and/or the third party contributors to this report make no representation or warranty that any data or information supplied to or by it or them is complete or free from errors, omissions, or defects. Without limiting the foregoing, in no event shall RepRisk AG and/or the third party contributors to this report have any liability (whether in negligence or otherwise) to any person in connection with the information contained herein. Any reference to or distribution of this report must include a link to the content to provide sufficient context. The information provided in this presentation does not constitute an offer or quote for our services or a recommendation regarding any investment or other business decision, and is not intended to constitute or to be used as a substitute for legal, tax, accounting, or other professional advice. Please note that the information may have become outdated since its publication. Should you wish to obtain a quote for our services, please contact us.

Decision‑grade means suitable for identifying and prioritizing risk exposure as an input into a broader decision‑making process. RepRisk data does not determine legality, compliance, thresholds, or required actions, and does not prescribe investment, procurement, or engagement decisions.

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