Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
Click a bar to drill down one level.
Where?
by regionAll jurisdictions
What for?
by action- Fine €72.5m 100 % · 11 cases
- Other – 0 % · 7 cases
- Order – 0 % · 5 cases
- Reprimand or warning – 0 % · 2 cases
Who?
by sectorAll sectors
- Financial services and insurance €63.3m 87 % · 7 cases
- Transport, logistics and shipping €8m 11 % · 3 cases
- Retail and e-commerce €1m 1 % · 6 cases
- Other €113,203 0 % · 1 case
- Energy and utilities €34,248 0 % · 2 cases
- Food and agriculture – 0 % · 4 cases
- Automotive – 0 % · 1 case
- Manufacturing and mechanical engineering – 0 % · 1 case
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 2 | €3.93m |
| 2023 | 4 | €18m |
| 2024 | 8 | €31m |
| 2025 | 10 | €15.1m |
| 2026 | 1 | €4.47m |
25 cases
11 Aug 2026 Fiducian Investment Management Services LimitedFiducian: 7.3 million AUD for misleading ESG claims about an ethical fund €4.47m
The Supreme Court of New South Wales, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed penalties totalling 7.3 million AUD on the fund manager: 2.3 million AUD for misleading statements (s 12DF ASIC Act) and 5 million AUD for breaching its duty of care and diligence as responsible entity (s 601FC(1)(b) Corporations Act). Between October 2019 and May 2024 the Diversified Social Aspirations Fund, marketed as socially responsible, held through underlying funds interests in companies that derived revenue from fossil fuels, among others, even though the product documents promised certain exclusions and ongoing monitoring; the company did not respond to investor concerns by amending its statements.
A fund's sustainability promises require ongoing checks of its actual holdings; where they diverge, either the holdings or the statements must be changed.
Substantiating ESG and ethical claims in product documents and fund marketing
Missing or inadequate training played a role in the decision.
- Authority / court
- Supreme Court of New South Wales (auf Antrag der Australian Securities and Investments Commission, ASIC)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- ASIC Act 2001 (Cth) s 12DF (Geldbuße nach s 12GBB); Corporations Act 2001 (Cth) s 601FC(1)(b) (Geldbuße nach s 1317G)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- Admissions, cooperation throughout the proceedings and contrition; since the proceedings began, an independent review of the product documents; no previous court findings.
- Liability of senior managers
- According to the agreed facts, senior management was involved (the company's then Executive Chair and Head of Investments).
- Published
- 12 Aug 2026
Original amount 7,300,000 AUD, converted at the ECB reference rate of 11 Aug 2026.
- Supreme Court of NSW – In the matter of Fiducian Investment Management Services Pty Ltd [2026] NSWSC 959 (Decision date 11.08.2026) Court decision
- ASIC 26-191MR – Court orders Fiducian Investment Management Services to pay $7.3 million penalty over operation of ESG fund (12.08.2026) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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4 Dec 2025 Eurowings GmbHDüsseldorf Higher Regional Court bans misleading Eurowings CO2 offsetting claims Order
On appeal by the Verbraucherzentrale Bundesverband (Federation of German Consumer Organisations), the Oberlandesgericht Düsseldorf (Düsseldorf Higher Regional Court) prohibited Eurowings from advertising a €9 CO2 offset during online booking in a way that makes customers believe they travel climate-neutrally; it was not mentioned that other climate-damaging emissions are not offset. By contrast, the court did not consider the 'Sustainable Aviation Fuel' advertising misleading; it did not grant leave to appeal on points of law.
Anyone selling CO2 offsets must point out that only part of the climate impact is offset, even if each individual statement is correct.
CO2 offsetting and climate neutrality in customer communication
- Authority / court
- Oberlandesgericht Düsseldorf, 20. Zivilsenat
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- UWG (irreführende Werbung); Az. I-20 U 38/25
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Transport, logistics and shipping
- Published
- 5 Dec 2025
Checked against the official source on 2 Oct 2026 · Direct link
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31 Oct 2025 JBS USA Food Company und JBS USA Food Company HoldingsNew York: JBS USA pays 1.1 million USD over unsubstantiated "Net Zero 2040" claims Other
The Attorney General's office accused the US arm of the meat group JBS of publicly advertising a "net zero by 2040" goal without a viable plan to achieve it. After a first lawsuit had been dismissed without prejudice in January 2025, the parties concluded an Assurance of Discontinuance: JBS USA pays 1.1 million USD to a climate-smart agriculture programme (expressly not a fine), changes its environmental marketing and reports annually for three years. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Net-zero promises are advertising claims and need a verifiable implementation plan, otherwise they are treated as misleading.
Communicating climate targets only with a robust implementation plan
- Authority / court
- Office of the New York State Attorney General
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- New York General Business Law §§ 349, 350; Executive Law § 63(12), § 63(15)
- Action
- Other
- Status of proceedings
- final
- Sector
- Food and agriculture
- Published
- 3 Nov 2025
- NY Attorney General press release: $1.1 Million for Climate-Smart Agriculture from World's Largest Beef Producer Press release of an authority
- Assurance of Discontinuance, People of the State of New York v. JBS USA Food Company (2025) Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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23 Oct 2025 TotalEnergies; TotalEnergies Electricité et Gaz de FranceParis Judicial Court: TotalEnergies advertising on climate neutrality misleading Order
In an action brought by Greenpeace France, Les Amis de la Terre and Notre Affaire à Tous, the Paris Judicial Court (Tribunal judiciaire de Paris, 34th chamber) found that TotalEnergies had advertised on totalenergies.fr with the goal of ‘carbon neutrality by 2050’ and its role as a player in the energy transition without disclosing that oil and gas production continues to be expanded – a misleading commercial practice. The court ordered the communication to cease, damages to be paid to the associations and the operative part of the judgment to be published on the website (RG 22/02955); claims relating to gas and agrofuels were dismissed.
Net-zero targets may only be advertised to consumers with reference to the actual business strategy.
Climate targets in consumer communication
- Authority / court
- Tribunal judiciaire de Paris (34. Kammer)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Art. L121-1 ff. Code de la consommation (Umsetzung der Richtlinie 2005/29/EG)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Energy and utilities
- Employees
- 10,000 or more
- Published
- 23 Oct 2025
Checked against the official source on 25 Sep 2026 · Direct link
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26 Aug 2025 Acqua Minerale San Benedetto S.p.A.AGCM: San Benedetto removes ‘CO2 neutral’ claim on Ecogreen bottles Other
Labels, the website and commercials for the Ecogreen line claimed that bottle production caused no greenhouse gas emissions and even had a positive effect on the environment. Following an intervention by Italy's competition and consumer protection authority (Autorità Garante della Concorrenza e del Mercato, AGCM) (moral suasion, case PS12596), the mineral water producer removed the claim ‘impatto zero CO2’ in mid-July 2025, revised nature motifs and added a QR code linking to sustainability information.
‘Zero emissions’ promises on packaging can hardly be substantiated; it is better to present specific reduction steps transparently.
Climate claims on packaging
- Authority / court
- Autorità Garante della Concorrenza e del Mercato (AGCM)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Codice del Consumo (unlautere Geschäftspraktiken), Verfahren PS12596
- Action
- Other
- Status of proceedings
- final
- Sector
- Food and agriculture
- Mitigating circumstances
- Voluntary amendment of all labels and advertising materials following the authority's intervention.
- Published
- 26 Aug 2025
Checked against the official source on 25 Sep 2026 · Direct link
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4 Aug 2025 Infinite Styles Services Co. Ltd (Shein)AGCM: 1 million EUR fine against Shein for misleading environmental claims €1m
Italy's competition and consumer protection authority (Autorità Garante della Concorrenza e del Mercato, AGCM) objected to vague and in part false claims about circular design and recyclability, about the ‘green’ evoluSHEIN collection (only a small share of the range) and about emission targets, while emissions rose in 2023/2024. The ultra-fast-fashion model is subject to a heightened duty of care, the authority held; it imposed 1 million EUR (case PS12709).
Communicate climate targets and recycling promises only if they are specific, substantiated and consistent with actual developments.
Verifiable sustainability communication in online retail
- Authority / court
- Autorità Garante della Concorrenza e del Mercato (AGCM)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Codice del Consumo (unlautere Geschäftspraktiken), Verfahren PS12709
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Retail and e-commerce
- Employees
- 10,000 or more
- Published
- 4 Aug 2025
- PS12709 - Italian Competition Authority: 1 million euros fine imposed on Shein for misleading and omissive green claims Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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30 Jul 2025 Kmart NZ Holdings LimitedKmart NZ warned over unsubstantiated “100% sustainably sourced cotton” claim Reprimand or warning
The Commerce Commission (ComCom, New Zealand's competition and consumer regulator) warned Kmart NZ Holdings Limited because, from 4 August 2023 to 4 October 2024, the company advertised own-brand clothing with the claim “100% sustainably sourced cotton” without being able to substantiate it: the cotton sourced as “Better Cotton” was mixed with conventional cotton in the supply chain. The authority considers a breach of s 12A Fair Trading Act 1986 (unsubstantiated representations) likely; only a court could determine one.
Absolute environmental claims such as “100%” require complete proof across the supply chain; a sustainability scheme whose raw material is mixed with conventional material does not support them.
Absolute sustainability claims in advertising only with complete evidence
Missing or inadequate training played a role in the decision.
- Authority / court
- Commerce Commission (ComCom), Neuseeland
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- s 12A Fair Trading Act 1986 (Neuseeland)
- Action
- Reprimand or warning
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Mitigating circumstances
- Kmart removed the claim from its New Zealand website after the authority raised it and stated that it continues to provide regular compliance training on consumer and competition law.
- Published
- 14 Aug 2025
- Commerce Commission: Kmart investigated and warned by ComCom for greenwashing advertising (14.08.2025) Press release of an authority
- Commerce Commission Case Register: Kmart NZ Holdings Limited (Kmart), PRJ0047592 Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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8 May 2025 Musinsa Co., Ltd., Shinsung Tongsang Co., Ltd., E-Land World Co., Ltd., ITX Korea Co., Ltd.Greenwashing on leather products: KFTC warns four fashion chains, including ZARA operator Reprimand or warning
The KFTC (Korea Fair Trade Commission, Korea's competition and consumer authority) found that Musinsa, Shinsung Tongsang, E-Land World and ITX Korea (operator of ZARA in Korea) had advertised leather products, including those made of synthetic materials, with blanket environmental terms such as 'eco' without sufficient evidence, and treated this as false, exaggerated and misleading advertising under the Labeling and Advertising Act. Because all four admitted the violations and corrected them voluntarily, it limited itself to warnings, issued between 2 April and 8 May 2025 (Shinsung Tongsang 2 April, Musinsa 10 April, E-Land World and ITX Korea 8 May); according to the KFTC it was the first sanctioned greenwashing case in the fashion sector.
Environmental claims such as 'eco' need a specific, substantiated reference to the whole product, otherwise they count as misleading.
Substantiated environmental claims in advertising and product labelling
- Authority / court
- Korea Fair Trade Commission (KFTC)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Art. 3 Abs. 1 Nr. 1 Act on Fair Labeling and Advertising (Labeling and Advertising Act; falsche oder übertriebene Werbung)
- Action
- Reprimand or warning
- Status of proceedings
- unknown
- Sector
- Retail and e-commerce
- Mitigating circumstances
- All four companies admitted the violations and corrected them voluntarily; the KFTC therefore limited itself to warnings.
- Published
- 15 May 2025
- KFTC press release (EN), 15 May 2025: Sanctions Imposed on Four Fashion SPA Business Operators for Violations of the Act on Fair Labeling and Advertising in Relation to Eco-friendliness Press release of an authority
- KFTC-Pressemitteilung (KO), 15.05.2025: 4개 패션 SPA브랜드 사업자의 부당한 광고행위 제재 Press release of an authority
- KFTC-Pressemitteilung (KO, PDF): Verwarnung (경고) der vier Unternehmen mit Datum je Unternehmen, Art. 3 Abs. 1 Nr. 1 표시광고법 Press release of an authority
Checked against the official source on 4 Oct 2026 · Direct link
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25 Mar 2025 Adidas (Sportartikelhersteller)Nuremberg-Fürth Regional Court: Adidas may not claim 'climate neutral by 2050' without explanation Other
On an action by a consumer association, the Landgericht Nürnberg-Fürth (Nuremberg-Fürth Regional Court) ordered Adidas to cease the former statement 'By 2050 we will be climate neutral' on its corporate website and to reimburse warning costs. The statement created the impression that the goal would be reached solely through the company's own emission reductions, although green electricity certificates were also to be used; a reference only in the linked annual report was not sufficient. According to the court's press release of 26 March 2025, the judgment was not final; whether an appeal was lodged is not known here.
Climate targets on a corporate website also count as advertising and must disclose there what role offsetting plays.
Climate targets on the corporate website as advertising
- Authority / court
- Landgericht Nürnberg-Fürth
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- UWG (irreführende Werbung); Az. 3 HK O 6524/24
- Action
- Other
- Status of proceedings
- unknown
- Sector
- Retail and e-commerce
- Employees
- 10,000 or more
- Published
- 26 Mar 2025
Checked against the official source on 2 Oct 2026 · Direct link
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18 Mar 2025 LGSS Pty Ltd (Trustee des Active Super Fonds)ASIC: 10.5 million AUD against LGSS (Active Super) for greenwashing on exclusion screens €6.12m
Following proceedings by the Australian Securities and Investments Commission (ASIC, the federal corporate and financial services regulator), the Federal Court of Australia on 18 March 2025 ordered LGSS Pty Ltd, trustee of the Active Super pension fund, to pay 10.5 million AUD and to send a notice of its misconduct to members and publish it on the fund's web pages. The fund had advertised that it excluded investments in, among others, gambling, coal mining and oil tar sands and, after the invasion of Ukraine, Russia, yet held such investments directly or indirectly; the court had found the breaches of the ban on misleading representations in June 2024.
Advertised exclusion criteria must be reflected in all holdings, including indirect ones; deviations must be detected and corrected on an ongoing basis.
Exclusion criteria and sustainability promises in fund marketing
Missing or inadequate training played a role in the decision.
- Authority / court
- Australian Securities and Investments Commission (ASIC) / Federal Court of Australia
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- ASIC Act 2001 (Cth) ss 12DB(1)(a) und 12DF(1); Strafe nach s 12GBB, Veröffentlichungsanordnung nach s 12GLB
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Mitigating circumstances
- The court accepted some contrition, cooperation with ASIC through attendance at voluntary conferences and compliance improvements (including ESG and consumer law training for the board, executive leadership and staff, and an external review of internal controls), but gave less weight to contrition and cooperation because of how the case was defended; the merger with another fund trustee reduced the weight of specific deterrence.
- Liability of senior managers
- LGSS accepted in the proceedings that senior management was ultimately responsible for the absence of properly functioning systems to prevent false ESG representations; the proceedings were brought against the company only.
- Published
- 18 Mar 2025
Original amount 10,500,000 AUD, converted at the ECB reference rate of 18 Mar 2025.
Checked against the official source on 3 Oct 2026 · Direct link
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21 Jan 2025 General Logistics Systems B.V., General Logistics Systems Italy S.p.A., General Logistics Systems Enterprise S.r.l. (GLS)GLS: €8m fine over misleading “Climate Protect” climate programme €8m
The AGCM (Autorità Garante della Concorrenza e del Mercato, Italian competition and consumer authority) fined General Logistics Systems B.V., General Logistics Systems Italy S.p.A. and General Logistics Systems Enterprise S.r.l. EUR 8,000,000 jointly and severally because the “Climate Protect” environmental programme was promoted with vague, unsubstantiated environmental claims and misleading certificates of offset CO2 emissions. Subscription customers, including micro-enterprises, also had to pay an unrequested climate contribution that clearly exceeded the programme's costs, while large customers were exempted. The authority classified this as an unfair commercial practice under Art. 20, 21, 22 and 26(f) of the Codice del consumo (Italian Consumer Code) and prohibited its continuation.
Climate contributions and offsetting promises must be voluntary, transparently calculated and verifiable; passing the costs of an environmental programme on to customers while using it for self-promotion risks greenwashing proceedings.
Communicating carbon offsetting and environmental claims accurately
- Authority / court
- Autorità Garante della Concorrenza e del Mercato (AGCM)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Art. 20, 21, 22 und 26 lit. f Codice del consumo (D.Lgs. 206/2005); Sanktion nach Art. 27 Abs. 9 Codice del consumo
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Transport, logistics and shipping
- Published
- 4 Feb 2025
- AGCM, Comunicato stampa PS12525 – Sanzione di 8 milioni al gruppo Gls per pratiche commerciali scorrette (04.02.2025) Press release of an authority
- AGCM, Provvedimento PS12525 (Adunanza del 21 gennaio 2025), General Logistics Systems B.V. u. a. Decision of an authority
Checked against the official source on 28 Sep 2026 · Direct link
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8 Nov 2024 Invesco Advisers, Inc.Invesco Advisers: 17.5 million USD for inflated ESG integration percentages €16.2m
From 2020 to 2022, Invesco told clients that 70 to 94 per cent of the parent company's assets under management were ‘ESG integrated’, but counted passive ETFs that did not take ESG into account and had no written definition of ESG integration. The U.S. Securities and Exchange Commission (SEC) imposed 17.5 million USD, a censure and a cease-and-desist order.
Sustainability metrics used in sales need a written definition and a traceable calculation.
Verifiable metrics in ESG marketing
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Investment Advisers Act of 1940
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- intentional
- Published
- 8 Nov 2024
Original amount 17,500,000 USD, converted at the ECB reference rate of 8 Nov 2024.
- SEC Charges Invesco Advisers for Making Misleading Statements About Supposed Investment Considerations Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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9 Oct 2024 two Italian providers of small electric carsAGCM: providers of small electric cars remove ‘100 % green’ advertising Other
On the websites for two small electric cars, the providers advertised with ‘100 % sustainable’, ‘100 % Green’, ‘zero emissions’ and ‘zero environmental impact’ without taking into account life-cycle phases or the emissions from electricity generation. Following an intervention by Italy's competition and consumer protection authority (AGCM) by way of moral suasion, the claims were removed.
Even for electric vehicles, absolute claims such as ‘zero emissions’ are misleading if manufacturing and electricity generation are left out.
Blanket environmental promises for electric products
- Authority / court
- Autorità Garante della Concorrenza e del Mercato (AGCM)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Codice del Consumo (unlautere Geschäftspraktiken)
- Action
- Other
- Status of proceedings
- final
- Sector
- Automotive
- Mitigating circumstances
- Voluntary removal of the claims following the authority's intervention.
- Published
- 9 Oct 2024
- AGCM, Suche nach Entscheidungen (Entscheidung 2024) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 9 Oct 2026 · Direct link
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25 Sep 2024 an Australian fund managerAustralian fund manager: 12.9 million AUD for misleading ESG screens €7.93m
The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 12.9 million AUD because the fund manager claimed in product documents, on its website, in a media release and in online appearances that an ethically oriented global bond index fund excluded issuers with significant business activities in, among others, fossil fuels. According to the court, around 74% of the fund's securities by market value had in fact not been screened against the ESG criteria; the court had already found liability on 28 March 2024.
ESG exclusions may only be advertised if they are actually applied to, and checked against, the entire portfolio.
ESG screening and product claims: aligning marketing with the actual index methodology
- Authority / court
- Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- ASIC Act 2001 (Cth) ss 12DF(1), 12DB(1)(a) und (e); Geldbuße nach ss 12GBA/12GBB
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Mitigating circumstances
- The company had identified the matter itself, reported it to ASIC and cooperated fully; the court applied a 25% discount for this.
- Published
- 25 Sep 2024
Original amount 12,900,000 AUD, converted at the ECB reference rate of 25 Sep 2024.
Checked against the official source on 7 Oct 2026 · Company name anonymised since 25 Sep 2026 · Direct link
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9 Aug 2024 a UK boiler manufacturerCMA: boiler manufacturer changes marketing of hydrogen-blend-ready boilers Other
The CMA was concerned that the manufacturer, by promoting the ability of its gas boilers to run on a blend of up to 20% hydrogen, gave the impression of an environmental benefit or of future-proofing consumers' heating. The company gave formal undertakings to change or remove such marketing claims, inform its installers and retailers and report to the CMA on compliance; it did not admit any breach of the law.
Environmental claims must reflect the actual benefit to consumers today – a technical option is not yet a climate benefit.
Environmental marketing claims (greenwashing)
- Authority / court
- Competition and Markets Authority (CMA)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Part 8 Enterprise Act 2002 (Undertakings nach section 219); Consumer Protection from Unfair Trading Regulations 2008
- Action
- Other
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Published
- 9 Aug 2024
- CMA, Fälle (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Company name anonymised since 9 Aug 2026 · Direct link
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2 Aug 2024 an Australian superannuation trusteeSuperannuation trustee: AUD 11.3m penalty for misleading sustainability claims €6.8m
On its website the superannuation trustee promoted seven investment options of its superannuation fund marketed as sustainable as excluding companies involved in carbon-intensive fossil fuels, alcohol production and gambling; in fact six of the seven options held interests in such companies. Following admissions, the Court imposed AUD 11.3 million and ordered a court-prescribed notice on the website for six months. It was ASIC’s first greenwashing case before the Federal Court.
Marketing claims about exclusion criteria need a control process that continuously checks actual portfolio holdings against the promises made.
Review and sign-off of sustainability claims in marketing and on websites
- Authority / court
- Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- ss 12DB(1)(a), 12DF(1) ASIC Act 2001 (Cth)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Early admission, full cooperation with ASIC, removal of the statements and clearer disclosure in an information booklet from April 2023.
- Liability of senior managers
- According to the Court’s findings, persons at senior management level were involved; there were no mandatory sign-off processes for website content.
- Published
- 2 Aug 2024
Original amount 11,300,000 AUD, converted at the ECB reference rate of 2 Aug 2024.
Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link
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27 Jun 2024 BGH: advertising with ‘climate neutral’ only permissible with explanation in the advertisement itself Order
A manufacturer of fruit gums and liquorice (not named in the official press release) advertised in a trade journal that it had produced all its products ‘climate neutral’ since 2021, although this was achieved partly through offsetting. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) prohibited the advertising following an action brought by the Centre for Protection against Unfair Competition (Wettbewerbszentrale): ambiguous environmental terms must be explained in the advertisement itself, since reduction and offsetting are not equivalent.
Companies advertising with ‘climate neutral’ must explain directly in the advertisement whether emissions are avoided or merely offset.
Legally compliant environmental and climate claims in advertising
- Authority / court
- Bundesgerichtshof (I. Zivilsenat)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- § 3 Abs. 1, § 5 Abs. 1, § 5a Abs. 1 und 3, § 8 Abs. 1 Satz 1 UWG
- Action
- Order
- Status of proceedings
- final
- Sector
- Food and agriculture
- Published
- 27 Jun 2024
- Bundesgerichtshof, Pressemitteilungen (Übersicht) (Entscheidung 2024) Court press release
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Jun 2026 · Direct link
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27 Mar 2024 three British fashion retailersCMA: three fashion retailers commit to clear environmental claims Other
Following an investigation into their fashion environmental claims, the three retailers gave formal undertakings to the UK Competition and Markets Authority (CMA): no vague terms such as ‘eco’ or ‘responsible’, clear information on recycled and organic content, transparent criteria for green ranges, correct filters and information on labels, and regular reports to the CMA. No breach of law was established.
Sustainability labels in online shops must be specific, verifiable and easy for customers to understand; blanket terms are not sufficient.
Wording of environmental claims in marketing and online shops
- Authority / court
- Competition and Markets Authority (CMA)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Consumer Protection from Unfair Trading Regulations 2008 (förmliche Verpflichtungszusagen)
- Action
- Other
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Published
- 27 Mar 2024
- CMA, Fallübersicht (Entscheidung 2024) Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Mar 2026 · Direct link
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20 Mar 2024 a Dutch airlineAmsterdam District Court: airline advertising on sustainable flying misleading Other
In a collective action brought by a foundation, the Amsterdam District Court (Rechtbank Amsterdam) found that 15 of the airline's advertising claims were misleading and unlawful: they suggested sustainable flying or that offsetting products actually compensate for the climate impact, although biofuels and reforestation reduce it only marginally. The airline bears the costs of the proceedings; further claims were dismissed.
Offsetting and SAF offerings must not create the impression of climate-neutral travel; associations can challenge such claims in court.
Climate claims and offsetting offers in customer communication
- Authority / court
- Rechtbank Amsterdam
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Wet oneerlijke handelspraktijken (Art. 6:193a ff. BW)
- Action
- Other
- Status of proceedings
- unknown
- Sector
- Transport, logistics and shipping
- Employees
- 10,000 or more
- Published
- 20 Mar 2024
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 20 Mar 2026 · Direct link
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5 Oct 2023 a Japanese fishing bait manufacturerBait manufacturer: surcharge for unsubstantiated 'biodegradable' claims for fishing bait €113,203
The bait manufacturer advertised four ranges of artificial fishing bait on packaging, its website and in promotional material – in some cases from April 2016 to February 2023 – as biodegradable even when left behind in the water after use. The company provided no substantiation for this biodegradability; following a cease-and-desist order of 19 December 2022, a surcharge of 17,740,000 JPY was imposed on 5 October 2023.
Environmental claims such as 'biodegradable' only hold with evidence for the specific environment in which the product actually ends up.
Greenwashing: substantiating environmental claims
- Authority / court
- Consumer Affairs Agency (消費者庁, CAA)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Art. 8 Abs. 1 und 3 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Other
- Culpability
- negligent
- Published
- 5 Oct 2023
Original amount 17,740,000 JPY, converted at the ECB reference rate of 5 Oct 2023.
- Consumer Affairs Agency (消費者庁, CAA), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 5 Oct 2025 · Direct link