This Guide aims to provide a framework for environmental impact claims used by investment funds (or fund-based products) available to retail investors in the EU.

Drafted with the contribution of members of a broad stakeholder working group, the Guide aims to assist financial institutions in a clear, accurate and non-misleading communication approach for the environmental impact of their financial products with two objectives:

  • To fight greenwashing which hinders the financing of the green transition by retail investors.
  • To provide a clear framework for financial institutions to protect them against legal, financial and reputational risks associated with greenwashing.


In the climate emergency, environmental impact claims for a financial product can be a major influence on retail investor decision-making. Good communication on the environmental impact of a financial product must allow retail investors to be correctly informed while encouraging the promotion and development of innovative products which can make a real contribution to environmental protection and the fight against climate change.


But the regulatory framework does not accommodate the concept of financial product environmental impact. In the absence of a clear regulatory framework, financial institutions face significant legal uncertainty and are exposed to legal and financial risks in the event of legal proceedings and sanctions. Recent accusations of greenwashing against financial institutions highlight the reputational risk to which they are exposed.


This Guide attempts to fill the gap by synthesising: (1) recent work on assessing the environmental impact of a financial product; and (2) different regulatory provisions which are applicable to environmental impact claims in the finance sector to articulate recommendations and examples of good and bad practices.


The recommendations support financial institutions formulate clear, cautious and transparent messages to retail investors. This approach will help the most ambitious financial institutions differentiate themselves from their competitors through continuing to develop an innovative offer and ensure their environmental impact claims are legitimate.


However this Guide should only be considered an interim step to assist financial institutions until there is a clear regulatory framework for environmental impact claims of financial products. Regulatory changes at EU and/or national level are needed to provide: a clear definition of investor environmental impact; a method for assessing investor environmental impact for listed and unlisted markets; and a dedicated label to enhance the most ambitious impact approaches.


About our funder and the project: This project is funded by the EU’s Horizon 2020 research and innovation program under Grant Agreement No 834345. LEVEL EEI aims at making the financial products contributing to energy efficiency and sustainable energy more competitive. This work reflects only the author’s view, and the funder is not responsible for any use that may be made of the information it contains.

This Guide is part of the Retail Investing Research Program at 2DII which is one of the largest publicly funded research programmes on the supply, demand, distribution and policy aspects of retail investment markets in Europe.


2DII today announced it is transferring stewardship of the Paris Agreement Capital Transition Assessment (PACTA) to RMI, formerly Rocky Mountain Institute. PACTA measures financial portfolios' alignment with various climate scenarios, including those consistent with the Paris Agreement. Under RMI’s stewardship, PACTA will remain a free, independent, open-source methodology and tool, and will continue to provide the financial and supervisory community with forward-looking, science-based scenario analysis to help users make climate-aligned financing decisions. RMI will invest in scaling up PACTA’s usability and applicability in day-to-day investment decisions as well as reporting requirements.

Access the full press release here: the coming weeks, we will update this website with additional information. For now, please note that all contact information remains unchanged.