Greenwashing & Limits of ESG Law: A Call for Regulatory Reform in India

Anand Patel

Introduction

In the recent times, Environmental, Social and Governance (ESG) considerations have started to gain more importance and prominence in the corporate sector. India has made various regulatory moves which mirror its economic growth and sustainability goals. This has been acknowledged by various bodies like the Reserve Bank of India (RBI) and even the Securities Exchange Board of India (SEBI), which has also made reforms recently, like the Business Responsibility and Sustainability Reporting(BRSR) framework and ESG related guidelines. The absence of frameworks to deal with issues like greenwashing, often leads to various challenges. India currently faces this problem, and this needs to be addressed.

Defining Greenwashing: The Mirage of Sustainability

The term greenwashing should be understood as the practice of misrepresenting the extent to which a financial product or investment strategy, or an entity product, services or initiatives, are environmentally or climate friendly, sustainable or ethical.[1] This can be used in relation to investment products and marketing of goods and services.

In easy words, greenwashing can be said to be a mirage of kinds. a “mirage,” where companies and firms create an illusion of environmental responsibility to attract customers and investors, even when their actual practices do not align with these claims. This is done with the motive to make the customers invest and engage with them. One of the main motives why companies use the method of greenwashing is to attract the public, Companies aim to gain a competitive advantage by presenting a “green image,” considering the contemporary times, where climate change is considered a very important issue.

“The incentive to make claims of these kinds arises from increased market demand for greener products and increasing consumer awareness of the way investments are made, or goods and services produced.”[2]. This is done keeping in mind, the rising interest of consumers in purchasing sustainable or eco-friendly products. Hence, the use of environmental and sustainability claims is becoming more common in marketing of consumer goods.[3]

Greenwashing creates a major barrier in addressing climate change. It deceives public into thinking that company or organization is taking greater environmental measures than it is taking, which leads to the promotion of misleading measures. This diverts attention from real and sustainable efforts needed to address the climate changes.

Greenwashing is often a planned strategy of businesses and is beyond the simple notion of lying, it is more complex because companies have pressure from customers who need eco-friendly products while also keeping in mind Environmental Social Governance (ESG) goals.  [4]

Motive behind Greenwashing

• Competitive advantage –The modern generation can be deemed as the most outspoken one in terms of morality. Movements like Just Stop Oil, show how seriously matters of environmental safety are taken. Consumers prefer to buy eco-friendly products, hence if companies present themselves to have a green image or tag, it ultimately helps them to stand out from their competitors.
• Investor pressure and growing demand for ESG – Investors usually like to run a check on the ESG ratings and performances before investing in them. This influences companies to develop a good image and ultimately resort to greenwashing.
• Regulatory avoidance and delay – Regulatory pressure can be said to be one of the reasons why companies feel the need to be morally responsible in the terms of environment. Some businesses however, just for the sake of these regulatory mechanisms, use greenwashing as a means to maintain conformity with law.
• Reputation management and crisis control – This is usually considered a very deceptive way to avoid accountability. This can be understood using the help of an illustration. Let’s assume, there is a cloth manufacturing company, ABC. Recently, they have been accused of violating certain environmental norms. This has very likely reduced their public image as a whole and people are now questioning their ways. In order to rebuild their image, they start launch a clothing line which is very eco- friendly. The motive behind this move is not because they care about the environment, but rather to reshape their tarnished image and build back consumer trust. Greenwashing manifests itself in several ways or its types (recognized by united nation)[5]:

1. False net zero claims – a company claim that it will reduce pollution to net zero but it does not have a credible plan to achieve that.

2. Misleading labels – use intentionally misleading labels such as green and eco- friendly these term easily misinterpreted as have no standard definition.

3. Exaggerating impact – the company promote product that it has a large environmental benefit but in reality it has small impact improvement ( can only full basic legal standard.

4. Highlight one positive and ignored other – companies highlight good environmental feature and hide the harmful feature.

5. Irrelevant claims – Saying product avoids illegal or non-standard practices that do not actually relate to it.

6. Isolated Sustainability Messaging – Promoting the sustainability of a product separately from the overall brand’s environmental impact, such as recycled garment made in a highly polluting factory (vice versa).

Understanding Bluewashing: Social Responsibility Deception– The term bluewashing was first used for companies that joined the United Nations (UN) global compact without genuine intent or those who failed to make real policy changes[6]. The name bluewashing comes from the blue colour of the UN flag which describes how some companies used their association with UN to appear or make illusion that they socially responsible and ethical even though they did not take real action or implement reforms.[7] The UN Global Compact is voluntary and non-binding, and there is no binding or monitoring mechanism. This allows companies to take advantage of their association with the UN for reputational advantage while also not to implement the ten principles on human rights, labour, environment, and anti-corruption. Bluewashing mirrors green washing and both of them a negative impact and outcome as they mislead consumers about company social responsibility that affect ESG and CSR.

Corporate Social Responsibility (CSR)

CSR is a self-regulating business model and approach where companies include social and environmental concern in their working, operation and interaction with customers. Through CSR companies balance and achieve goal of economic, environmental and social wellbeing. This is also known as triple bottom line[8]. CSR can be said to be a long-term strategy and part of business. CSR overlaps with the concept of ESG, where companies take actions that are either voluntary or compulsory to enhance gains other than monetary gains. Basically, people who push the idea of CSR vouch for businesses acting amorally, i.e., they should in some way or another, contribute to the welfare of their communities.[9]

The United Nations Industrial Development Organization (UNIDO) promotes CSR for small and medium-sized enterprises using the Triple Bottom Line approach. This helps them meet social and environmental standards while still staying profitable.

In India, both CSR and ESG coexist together but there is a shift toward ESG. But INDIA is the country where CSR was done mandatory by law under the Companies Act, 2013. Section 135[10] of the Companies Act, 2013, mandates companies to spend 2% of their average net profit to CSR activities or goals, which is monitored by the ministry of corporate affairs.  Additionally, under section 134[11], companies must report CSR activities in the Board report. [12]

Rise of ESG as a central theme in corporate decision-making

ESG is no longer limited to CSR and reports. Its principle has become core part of corporate governance and business operations how will company interact with investor and customers. We have moved on from terms like “socially responsible investing” (SRI) and “corporate social responsibility” (CSR) to the more comprehensive and structured ESG framework.

The idea behind ESG can be traced back to early principles followed by religious groups like Quakers and Methodists. The Quakers in 1758, officially banned their members from participating in practice of slave trade owing to  moral grounds[13]. Similarly, Methodist founder John Wesley delivered a sermon titled “The Use of Money,” outlining the basic tenets of social investing, including we “ought not to gain money at the expense of life or by losing our souls.”

Emergence of ESG in the 20^th century:

• Pax world fund in 1971 launched in US was first ethical fund to avoid investment of churches into weapons manufacture and in Vietnam was known as first and started socially responsible investing.
• 1984: The UK got its first ethical unit trust – stewardship trust make investment in companies that positively will contributing to society and removed them which involved in arms, tobacco and other harmful to society.
• 1987 – Brundtland Commission and the Birth of “Sustainable Development” the report of our common future introduced sustainable development become foundation of environmental, social and economic goals.

ESG in the 21^st century

• 2004: The UN Global Compact coined the term ESG in its “Who Cares Wins” report. The report emphasised that companies that integrate ESG factors, affect not only long term profitability but also the society as a whole[14].
• 2006: “The Principles for Responsible Investment (PRI) were launched giving investors framework to took ESG into practice globally under UN supervision”.[15] Laid down the six principle for responsible investing by PRI an international organization made to promote ESG integration in investment decision making,
• Environmental Disasters: Events such as Bhopal gas tragedy and the BP oil spill gives alarm about environmental risks of doing business. These disasters made corporate governance accountability and directly influencing the need for ESG framework.
• Green Building Certifications like BREEAM, ENERGY STAR and LEED provide validation of company ESG performance this builds trust of customer, employee and investors. These certified company enjoyed high market value that “began to convince companies that it was in their interest to factor ESG into decision-making”.[16]

In early 2000s CSR practice was formalized due to the pressure from investor, government and consumer (demanding for the accountability and transparency). That lead to ESG which give standardized metrics of company impact on environment, social and governance. ESG become mainstream in corporate decision making. Furthermore SDDGs goal of 2015 by UN make ESG more important as if need to attain these goals.

Challenges and Gaps in ESG Implementation and Reporting

1. Distinction Between Impact-Based and Risk-Based ESG Ratings

Impact based rating – focus on impact (positive or negative) that a company do on environment, social and governance, focus on the company effect on word.

Risk based rating – focus on how the ESG factor making impact or risk to company financial performance and value, look at how the world affecting the company. only concerned with how a company’s exposure to climate, social and governance risks can affect its bottom line.[17]

Misunderstanding created from this – mostly people believe that ESG rating tell that how much company making positive impact on world. But they don’t know that it is a risk based rating and the company protects its own value. This creates confusion for investors as they think they have put money into positive ESG supporting companies.

2. No  Universal  Standard Method for ESG Ratings

When a Company  receive ESG rating or performance score that depend upon which agency or organization is giving it, as till there is no single standard method or set of indicator  this create major problem of which rating is authentic and believed. 

• Bloomberg ESG Data Service take about 120 indicators to get company ESG performance.
• Thomson Reuters ESG Research use more than 400 indicators.

For Companies: they will not know what to improve or a company improve an indicator but that does not come under certain rating agency. Their effort gone waste as not recognized.

For Investors – become difficult for them to invest as rating does not clearly give understanding which performing positively for ESG.

According to World Economic Forum that many companies rely on self-made frameworks and choose specific indicators that are often developed within their own industries, without any formal regulatory supervision. 

3. Tribunal Jurisdiction in India

As in India there is grow in companies that are adopting ESG standard but in India problem arises who have the jurisdiction on the matter related to the ESG DISPUTE as both corporate and environmental issues are involved in it.  Jurisdiction problem involved between NGT[18] and NCLT[19].

NGT – created in 2010 to address environment related cases and can take case on its own ( Suo moto ).

NCLT – created in 2016 to address company legal issues include corporate social responsibility (CSR[20]) violation and insolvency cases empowered by companies act 2013 and gives exclusive jurisdiction.

This create a grey area in ESG jurisdiction as no single tribunal has complete authority because of this confusion parties can choose which tribunal benefits or give favourable outcome to them. [21]And if both tribunal took the case and give different ruling this will result in long litigation and delayed justice that would slow down the growth of ESG.

4. Why Is ESG Compliance a Challenge for Businesses?

ESG laws are frequently changing that a significant problem to companies to adapt new rules  and maintain profitability of company. International companies function in different nation and every country has its standard and indicator that makes difficult to them what for ESG they need to improve.

5. Ensuring Transparency and Accuracy in ESG Reporting

The Problem of Greenwashing and ESG Data Misrepresentation – companies that fails to get trusted ESG report and company has risk of facing regulatory penalties, investor withdrawals, and reputational damage. Then the practice of misleading is taken place by making sustainability claims. And some time company get report from that agency that has different indicator that benefit the company.

6. Loophole in ESG materiality assessment

There is the “assumption that all ESG factors hold equal relevance across different sectors”. But every industry or sector has different factor and it impact will specific[22]. But treating it universally equal make generic report and not tell true impact that make difficult to companies to address real risk and their effort are too thin broad factor to address.

Key ESG Reforms and Regulations Introduced in India

1. Mandatory BRSR (Business Responsibility and Sustainability Reporting) report introduced by SEBI in 2021 and made it mandatory from the 2022-23 financial year , it is for top 1000 listed companies by market capitalisation to report voluntarily, with mandatory reporting from 2023.[23]

The report is based on 9 principles: the “National Guidelines on Responsible Business Conduct (NGBRCs), issued by the Ministry of Corporate Affairs (MCA) in 2019”. It also matches the global standard and covers ESG indicators.

2. BRSR core and Value Chain Disclosures introduced by SEBI in 2023

SEBI introduced new rules for the top 250 listed companies in India. These companies must report ESG data with  including  of value chain.[24] Value chain refers to all the aspects of a company‘s operations, including upstream operations like suppliers and downstream operations such as distributors, retailers and partners[25].

A holistic regulatory framework for corporate governance gives more transparency in the company and its supply chain, accountability,  India is creating Key Performance Indicators(KPI) which are specific,  measurable, which are relevant to Indian companies today[26].  TBRSR Core – limited set of key ESG indicators, mandatory third-party assurance and Value Chain Disclosures.

3. Green Credit Program under BRSR

Green Credits can be generated by a listed company and its value chain partners through plantations of trees on waste or degraded lands and river catchment areas”  added as indicator under Principle 6 of BRSR, that businesses should respect and make efforts to protect and restore the environment.[27] Checked and disclosure with Ministry of Environment, Forest and Climate Change. company discloses ESG information about value chain and  also required to disclose the percentage of total sales and purchases covered by this information.

4. Reserve Bank of India (RBI) reforms for ESG

Climate Risk Disclosures (Draft Framework) – mandatory climate-risk disclosure rules for banks and large NBFCs that covering governance, strategy, risk management, with detailed metrics by FY 2026 and full disclosure from FY 2028 onward.[28]

5. GFIN greenwashing Techsprint held in UK in 2023 purpose to bring international regulators and firms and aim to solve ESG greenwashing “by developing a tool or solution that could help regulators or the market more effectively tackle or mitigate the risks of greenwashing in financial services.” [29]From India RBI has participated in it with 15 international regulators.

6. On June 5 2025, SEBI introduced new rulebook for ESG debt securities – gives new guideline for companies that how will they raise capital or money through special types of bond. [30]But it does not include GREEN bonds (under SEBI’s 2017 framework) because it has already separate framework. But it will cover

• Social Bonds – to fund that will help society to grow such as building schools and hospital (positive social outcome)
• Sustainability Bonds – These combine both environmental and social goals (planet and people mix of environmental and social projects )
• Sustainability-Linked Bonds (SLBs) – the company can use funds for anything, but it must meet specific sustainability goals like reducing carbon emission and if it fails will face penalty. (financial and reputational of the issuer is linked to their achievement of measurable ESG goals)

Before this companies dis voluntary ESG claims and issue bonds without any checks. This false claim done to attract investor this known as purpose washing.

Greenwashing: A Hidden Threat to ESG Credibility

• Affects investor confidence – as investors rely on ESG rating which is manipulated by the greenwashing tactics.
• Undermines Genuine ESG Performers – Companies that actually invest in green transitions will be less competitive compared to greenwashed companies who achieve better rating with lower costs.
• Dilutes Stakeholder Trust – Consumers and public lose belief in eco-labels, sustainability, and ESG scores also damaging the entire ESG credibility.

Greenwashing is not just an ethical concern but systemic threat to credibility, utility, and integrity of ESG frameworks. For country like India which is trying to grow economically while protecting the environment it becomes important to control greenwashing.  If not addressed greenwashing will undermine India climate goals, mislead investors, and create an ESG problem that lacks real activity.

Contemporary examples of Greenwashing:

• Volkswagen

In 2015 U.S. An Environmental Protection Agency (EPA) found that German motor vehicle manufacturer Volkswagen manipulated the federal emission test. Volkswagen had used and fit software into many of its vehicles that could detect when an emissions test was being carried out. During these tests software automatically reduce the amount of pollution the engine produced making, the cars look more eco-friendly than they actually were. Volkswagen later admitted manipulation on tests and company CEO resigned soon after the scandal became public. The company was hit with approximately $30 billion in fines and settlements from regulatory bodies around the world.

• FIFA

FIFA faced public criticism after stating that its 2022 World Cup would be carbon-neutral but when FIFA later gave the report detailing its sustainability strategy many climate experts and environmental organizations found flaws with it[31]. In 2023 the Swiss Fairness Commission reviewed the concern and concluded that FIFA made misleading claims about environmental impact. This case tells that organizations should be caution to terms like carbon-neutral.

India’s Regulatory Landscape for ESG and Anti-Greenwashing

There is no direct or standalone law for targeting the greenwashing done by the companies or other organization. India has many overlapping and combination of law addressing it. Some of them are :

• Consumer Protection Act 2019 – it is most important laws as it protect consumer rights and greenwashing “unfair trade practices” against consumers. Section 2(47) of the Act defines “unfair trade practices broadly meaning misleading representations concerning the quality of products, goods or services”.  So greenwashing falls under it as it will involve false and vague claims about product or service that it benefit environment. The issue with this is harm or deception is done than the action is taken under it.
• Central Consumer Protection Authority – under Ministry of Consumer Affairs has announce strict guideline for stopping and regulating greenwashing. Such guideline will set to regulate enviro. claims in advertising.[32] However, enforceability is limited and no provision is statutory.
• Advertising Standards Council of India – ASCI check all channels of advertisement and complaints against misleading environmental ads. The decision of ASCI are not strictly legally enforceable but have to change the unethical ad. (limitation – ASCI is  self-regulatory body also its rulings are not legally binding.)
• Reserve Bank of India – “Framework for Acceptance of Green  Deposits,”  validate the green investment product environmental effect, check third party verification and the green fund allocated its impact assessment. This helps in avoid labelling green product through false claim. (limitation – that is only limited to banks and for green deposit but claims of outside sector are not included )
• Securities and Exchange Board of India – SEBI introduced new rulebook for ESG debt securities and Mandatory BRSR.

These regulations are framed to save specific sectors, as India currently lacks comprehensive anti-greenwashing laws . The current laws are weak and no single government organization for implementation. In India, like many other issues, awareness about greenwashing among consumers is very low, and it would take time for us to achieve that.

Suggestion – A single dedicated law for greenwashing under environment or consumer protection act, making uniform and global standard certification for claims and make an independent organization to prevent greenwashing,

Reforms in EU and USA to counter greenwashing

• European union – the Green Claims Directive

EU introduced extensive regulation for environmental claims, and its aim is to prevent greenwashing that for consumer trust. In March 2024 EU Parliament adopted the draft, which is now entering the trilogue phase. The Green Claims Directive was expected to come into force in 2027.

According to the draft Green Claims Directive companies must provide consumers with evidence of voluntary environmental claims. The draft gives out clear criteria for how companies must prove their environmental claims and labels, Environmental claims must also be verified by independent and accredited verification body before publication. [33]The draft directive also contains rules on ecolabels to ensure that they are reliable.

In June 2025, the European Commission officially withdrew the proposed Green Claims Directive (GCD) Citing various reason for it. [34]

The Unfair Commercial Practices Directive (UCPD) and The Empowering Consumers for the Green Transition Directive (ECGT) is the current regulation.

• USA – Federal Trade Commission (FTC) Green Guides

aim of Green Guides is to “help marketers avoid making environmental marketing claims that are unfair or deceptive” to prevent deceptive claims. state qualifications and disclosures should be clear, prominent, and understandable. 

These guidelines are administrative interpretations of the law and do not a private right of action, but FTC can take action if company makes an environmental claim that is inconsistent with guidance provided.

Recommendations for Strengthening India’s Anti-Greenwashing and ESG Framework

• Making standard verification of green claims and clear definition.
• Making government organizations or third parties who regulate and give green labels to companies. One high authority is needed as currently SEBI, CCPA, ASCI, RBI, and MoEFCC lack the coordination.
• Improving Regulatory Coordination and Enforcement
• India should launch nationwide public awareness campaigns to educate consumers and investors about greenwashing, its various forms, and practical ways to identify misleading claims.
• India’s Companies Act (Section 166(2) and Schedule 4) philosophically embraces a “pluralistic” corporate governance model, placing stakeholder interests, including those of the environment and community, on par with shareholder interests.

CONCLUSION

Although there have been reforms implemented by India, like the BRSR and the ESG debt securities framework, the lack of proper anti- greenwashing laws weakens the overall regulatory architecture. So firstly, India needs to come up with a proper regulatory framework that addresses the issue of greenwashing. This is important as greenwashing as a practice is very deceptive and misleads not investors but also the consumers that show faith in the companies only on the fact that these companies are contributing to the overall wellbeing of the environment. To achieve this, it would take coordination,  transparency and adequate reforms that are implemented properly.

Referance

[1] Australian Sec. & Inv. Comm’n, INFO 271: How to Avoid Greenwashing When Offering or Promoting Sustainability-Related Products (June 2022),https://asic.gov.au/regulatory-resources/financial-services/how-to-avoid-greenwashing-when-offering-or-promoting-sustainability-related-products/#Prohibitionsagainstmisleadinganddeceptiv/

[2] Law Council of Australia, Submission No. 4403 – S: Greenwashing at 2 (Nov. 3, 2023)

[3] Ibid.

[4] Corporate Greenwashing Strategies, Fashion Sustainability‑Directory (Apr. 2025), https://fashion.sustainability-directory.com/term/corporate-greenwashing-strategies/

[5] U.N., Climate Issues: Greenwashing, Deceptive Tactics Behind Environmental Claims, https://www.un.org/en/climatechange/science/climate-issues/greenwashing (last visited June 10, 2025).

[6] Timothy J. McClimon, Bluewashing Join Greenwashing will be New Corporate Whitewashing, Forbes (Oct. 3, 2022).

[7] ibid

[8] United Nations Industrial Development Organization, What Is Corporate Social Responsibility (CSR)?, UNIDO (last visited June 13, 2025) “https://www.unido.org/our-focus-advancing-economic-competitiveness-competitive-trade-capacities-and-corporate-responsibility-corporate-social-responsibility-market-integration/what-csr”

[9] Solihin Ismail, Corporate Social Responsibility (CSR) (Salemba Empat 2009).

[10] Companies Act, 2013, § 135 (India).

[11] Companies Act, 2013, § 134 (India).

[12] Umakanth V.  Legal and Regulatory Impetus for ESG in India- Developments and Challenge NUS Law Working Paper No. 2023/003 (Jan. 2023), https://law.nus.edu.sg/wp-content/uploads/2023/01/03_UmakanthVarottil.pdf.

[13] Corporate Knights –  Short History of Responsible Investing, Corporate Knights (May 11, 2021), https://www.corporateknights.com/responsible-investing/a-short-history-of-responsible-investing/

[14] Today-ESG, Origin of ESG – Global Compact “Who Cares Wins”, TodayESG (Jan. 3, 2023), https://www.todayesg.com/origin-of-esg-global-compact-who-cares-wins/ (last visited June 16, 2025)

[15] Persefoni, UN PRI: What Businesses Need to Know, Persefoni (Apr. 12, 2024, updated Sept. 4, 2024), https://www.persefoni.com/blog/un-pri.

[16] Corporate Governance Institute, A Brief History of ESG: From Pioneer to Mainstream, Corporate Governance Institute.

[17] Shuchi Agrawal, The Broken Promise of ESG Investing, IndiaCorpLaw (May 6 2024), https://indiacorplaw.in/2024/05/the-broken-promise-of-esg-investing.html.

[18] The National Green Tribunal Act, No. 19 of 2010, Acts of Parliament, 2010 (India).

[19] The Companies act, No. 18 of 2013, § 410, Actsof Parliament, 2013 (India).

[20] The Companies act, No. 18 of 2013, § 280, Act of Parliament, 2013 (India).

[21] Kavya Agrawal, ESG Integration in India: Challenges, Progress, and Future Directions, 6 Indian J. L. & Legal Rsch. (Issue VI) (Dec. 6, 2024), https://www.ijllr.com/post/esg-integration-in-india-challenges-progress-and-future-directions.

[22] Apiday, five Mistake to Avoid in Corporate ESG Reporting Apiday (July 2, 2024)

[23] Council on Energy, Environment and Water Explained: What Is BRSR? CEEW (May 29, 2024), https://www.ceew.in/gfc/quick-reads/explains/brsr.

[24] SEBI, Circular – SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122, Mandating ESG Disclosures for Value Chain of Top 250 Listed Companies (July 12, 2023).

[25] Melissa Cyrill, ESG Reporting in India BRSR Core, ERP Rules, & ISSB Standards, India Briefing (July 25, 2023), https://www.india-briefing.com/news/brsr-reporting-in-india-key-changes-to-esg-disclosures-introduced-by-sebi-36261.html.

[26] Ibid.

[27] Press Trust of India, SEBI Includes Green Credit Program under BRSR Framework, Business Standard.

https://www.business-standard.com/markets/news/sebi-includes-green-credit-program-under-brsr-framework-125032801374_1.html (last visited June 20, 2025)

[28] India central bank releases draft disclosure framework for banks to address climate risks, Reuters (Feb. 28, 2024), https://www.reuters.com/world/india/india-cenbank-releases-draft-disclosure-framework-banks-address-climate-risks-2024-02-28/ (last visited June 20, 2025)

[29] Global Financial Innovation Network. GFIN Greenwashing TechSprint, Global Financial Innovation Network (2023), https://thegfin.com/greenwashing-techsprint (last visited June 22, 2025)

[30] The ESG Institute – India ESG Bond Revolution Inside SEBI New Framework for Social, Sustainability and Sustainability-Linked Bonds, ESG Institute (June 13, 2025), https://www.the-esg-institute.org/blog/india-esg-bond-revolution-inside-sebis-new-framework-for-social-sustainability-and-sustainability-linked-bonds.

[31] Example of Greenwashing Claim TechTarget – Sustainability https://www.techtarget.com/sustainability/feature/Examples-of-greenwashing-claims(last visited June12, 2025)

[32] Ministry of Consumer Affairs, Draft Guideline for the Prevention and Regulation of Greenwashing or Misleading Environmental Claims 2024 (Feb. 20, 2024), https://consumeraffairs.nic.in/sites/default/files/file-uploads/latestnews/Draft%20Guidline%20with%20approval.pdf.

[33]  Anna‑Kristine Wipper and Manuela Meyer, What the Green Claims Directive Means for Companies – An Overview KPMG Law Insights https://kpmg-law.de/en/what-the-green-claims-directive-means-for-companies-an-overview/ (last visited June 25, 2025)

[34] Withdrawal of the Green Claims Directive Means for Environmental Marketing in the EU, ASUENE Blog (updated June 25, 2025), https://asuene.com/us/blog/the-withdrawal-of-the-green-claims-directive-what-it-means-for-environmental-marketing-in-the-eu.