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By Dara INGALLO, senior knowledge lawyer, funds and asset management, AO Shearman Valentina NOBMANN ANZOLA, juriste, funds and asset management, AO Shearman
On 14 January 2026, ESMA published its second thematic note on “clear, fair, not misleading sustainability-related claims”, this time focusing on how firms communicate ESG integration and ESG exclusion strategies in non-regulatory communications.
Coming just six months after the first note (issued in July 2025) on ESG credentials, including labels, awards, industry initiatives, and peer comparisons, the second note signals intensifying regulatory scrutiny of sustainability messaging and the growing importance of precision in ESG-related investor communications.
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