EU Retail Funds’ Environmental Impact Claims Do Not Comply with Regulatory Guidance

2DII reviewed the marketing material associated with a sample of 230 European funds (ESG funds, green equity funds, green bond funds) and analyzed the environmental impact claims against the criteria of the regulatory guidance.

Key Findings


According to an in-depth analysis of a sample of 230 “sustainability-themed” European funds, 2DII finds that 52% of them made environmental impact claims of some kind.


99% of these claims were misaligned with guidance that requires them to be specific, unambiguous and substantiated.

52% of funds are associated with ‘investor impact’ claims as defined by academic literature: they claim that retail investors will create environmental benefits in the real economy by investing in their funds, in a way that suggests measurability and additionality of the impact.

99% of the claims do not comply with the regulatory guidance on environmental claims (EU Multi-Stakeholder Dialogue on Environmental Claims) associated with the Unfair Commercial Practices Directive.

The main issues relate to confusing ‘investor impact’ and ‘company impact’ and confusing the evolution of the exposure of the fund (to carbon emissions) with ‘investor impact’.

This project was made possible by

Hewlett Foundation