The EU's rules on green claims from September 2026
Directive (EU) 2024/825, which amends EU consumer law for the green transition, applies from 27 September 2026. It bans generic environmental claims such as 'green', 'eco-friendly' or 'climate friendly' unless the company can show recognised excellent environmental performance relevant to the claim; claims that a product has a neutral, reduced or positive climate impact because of offsetting; sustainability labels not based on a certification scheme or set by public authorities; and claims about a whole product or business that apply only to part of it. It governs consumer-facing communication, so report content repurposed into marketing falls squarely under it.
CSRD, assurance and the data behind the words
The Corporate Sustainability Reporting Directive (EU) 2022/2464 requires companies in scope to report under the European Sustainability Reporting Standards, with limited assurance from an auditor. Amendments adopted in 2026 narrowed its scope to much larger companies, broadly those with more than 1,000 employees and over €450 million turnover, so check which rules now apply to you. Whatever the scope, the narrative and all content derived from it must match the reported data exactly: the same figures, units, rounding and boundaries, such as scope 1, 2 and 3 emissions under the GHG Protocol. Listed EU companies also file annual financial reports in the European Single Electronic Format, and the designed report must match the tagged figures.
Imagery must show the real operation
The easiest way to greenwash is with pictures. Wind turbines the company does not own, forests beside a factory that sits in an industrial estate, electric trucks when the fleet is diesel, or a generated 'sustainable facility' that does not exist all mislead. UK regulators have upheld complaints against energy companies whose ads showed only their low-carbon activities while leaving out the rest of the business. Photograph real sites, projects and people; where an image illustrates a plan or target, label it as such with the date the plan applies. Generated imagery can serve abstract themes and data visualisation, not scenes that imply current operations.
Accuracy, consistency and the UK standard
The UK's Competition and Markets Authority applies its Green Claims Code: claims must be truthful, clear, complete, fair in comparison, consider the full life cycle and be substantiated. Since April 2025 the CMA can fine businesses directly for consumer law breaches, up to a tenth of global turnover. Content across the report, website, social posts and investor materials has to say the same thing, so keep one approved claims register and generate everything from it. The studio stores approved claims and banned words in the brand hub, so terms such as 'carbon neutral' can be blocked at generation, and routes each asset through sign-off with an audit trail.
Updated 25 September 2026