This article explores notable findings in the ESAs’ recent reports on greenwashing risks and related policies, which indicate regulators’ likely areas of focus when horizon scanning, monitoring and regulating greenwashing. In this context, the range of scenarios that are likely to be subject to regulatory supervision will likely continue to grow.

To mitigate greenwashing risks, firms can draw lessons from the ESAs’ reports, including their common high-level understanding of greenwashing, and the key channels and sustainability topics which the ESAs consider to be high-risk areas.

Please get in touch with the authors Matthew Townsend, Ying-Peng Chin, Claire Haydon, Danae Wheeler or Sam Jones, or your usual contact at Allen & Overy LLP if you would like to discuss any aspect of this article.