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A comment on ESMA’s thematic notes on transition and impact claims

Bosco Verticale is a building designed to minimize it's negative environmental impact and promoting human health by using energy-efficient designs, renewable energy, sustainable materials, and water conservation throughout the building's entire lifecycle.
Photo: Massimo Ravera/Getty Images

ESMA’s new notes turn “substantiated” into a concrete evidential standard: Applies to marketing, voluntary reporting, and oral communications.

On October 12, 2026 ESMA published the third and fourth notes in its series on clear, fair, and not misleading sustainability-related claims: one on impact claims, one on climate transition claims. The four headline principles remain unchanged: accurate, accessible, substantiated, and up-to-date.

What has changed is that, for the first

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