Greenwashing and greenwishing

A regulatory view

Driven by a regulatory tsunami and an ever-growing investor demand for solutions towards sustainable development, sustainability has found its way into the core businesses of financial institutions which have largely started to recognise sustainability not only as a risk, but also as an opportunity. The growing appetite for sustainable financial solutions, however, paired with the complexity of regulations comes with the risk of financial institutions misleading clients and investors about the (un)sustainable characteristics of their financial products and services. This so-called ‘greenwashing’ comes in many different forms – including ‘greenwishing’, when financial institutions truly believe in ESG but fail to achieve the communicated and intended impacts and results. As a consequence, regulators are now taking a closer look into the risks related to greenwashing and greenwishing. This PwC study examines the topic from a regulatory perspective, helping financial institutions grasp the essence of greenwashing and providing them with direction in the fast evolving field of sustainable finance.

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Key findings

Greenwashing definitions

The comparison of definitions reveals that all authorities share a common basic understanding of greenwashing; however, varying specifications and focal points can be identified which reflect the complexity and multi-faceted nature of greenwashing and, to some extent, diverging supervisory expectations on this topic.


Greenwashing challenges financial institutions in that it can materialise into financial risks, as the green regulatory tsunami increases the legal and reputational risks related to greenwashing. These risks are amplified in cases of cross-border activities, as institutions need to simultaneously comply with varying national and international regulations aiming at creating more transparency and less greenwashing.

Prevention and controlling

In order to prevent greenwashing, financial institutions must be able to identify, manage and monitor greenwashing risk. This requires dedicated internal functions to be tasked with the responsibility of the ongoing review and control, including monitoring the effective implementation of the ESG strategy and the practical application of relevant ESG data and KPIs in the investment process.


The study highlights the developments with regard to Swiss and international supervisory authorities and their approaches to defining and tackling greenwashing risks. By analysing relevant supervisory guidelines and definitions, the study maps similarities and differences in the supervisors’ understanding of greenwashing and elaborates on the challenges faced by financial institutions in light of increasing greenwashing risks and a variety of supervisory approaches. Finally, the study presents possible ways for financial institutions to reduce their exposure to greenwashing risks as well as a framework for doing so.

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Analysis of definitions of greenwashing from supervisory authorities around the world, including Switzerland, EU, Germany, France, UK, USA, Hong Kong and Singapore.

Collection and mapping of greenwashing scenarios from misleading fund names to confusing disclosure methods in order to reveal common patterns and focus areas..

Elaboration on challenges, strategies and a facilitated framework to prevent and manage greenwashing risks.


«The green regulatory tsunami increases legal and reputational risks related to greenwashing. This study provides guidance to financial institutions in the rapidly evolving field of sustainable finance.»

Dr. Antonios KoumbarakisSustainability & Strategic Regulatory Leader, PwC Switzerland

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Contact us

Dr. Antonios  Koumbarakis

Dr. Antonios Koumbarakis

Partner, Sustainability & Strategic Regulatory, PwC Switzerland

Tel: +41 58 792 45 23

Sofia Jaccard

Sofia Jaccard

Senior manager, Sustainability & Strategic Regulatory, PwC Switzerland

Tel: +41 58 792 26 87

Lara Rossi

Lara Rossi

Senior Associate, Sustainability & Strategic Regulatory, PwC Switzerland

Tel: +41 58 792 43 47