Greenwashing Risk Management: Understanding Regulatory Expectations

First published by the Compliance Institute in the Irish Compliance Quarterly (ICQ) Spring 2026 edition.

In Greenwashing Risk Management: Understanding Regulatory Expectations, ALG’s ESG & Sustainability Lead, Jill Shaw, considers the guidance on sustainability claims and greenwashing risks being provided by the European Supervisory Authorities (ESAs) to those in the financial services sector within their supervisory remit.

This article emphasises that misleading sustainability claims raise investor protection concerns. Drawing on the ESAs’ final reports on greenwashing, it highlights that these reports provide examples of actions that can be taken to mitigate the risk of greenwashing when making sustainability claims. It also outlines what is covered in the subsequent related thematic notes prepared by the European Securities and Markets Authority (ESMA) and how these resources can be used when designing compliance processes to mitigate greenwashing risk.   

For further information on this topic, please contact Jill Shaw, ESG & Sustainability Lead or any other member of the ESG & Sustainability Team.

Date published: 23 March 2026