Integrity Monitor analyses more than 2,200 environmental statements across the main European markets
Milan, 25 September 2026 – The environmental communication of Europe's large companies meets the new anti-greenwashing rules with a significant level of exposure. Of 2,233 environmental claims made by the largest listed companies in Italy, France, Germany, Spain and the United Kingdom, 2,179 — about 98% — show at least one risk indicator under the screening carried out by Integrity Monitor, a Milan-based intelligence, data management and risk analysis company, through its Reputation Index.
The analysis does not establish that these claims constitute breaches of the law. It measures their degree of exposure to risk instead, putting them through a stress test built on the criteria introduced by Directive (EU) 2024/825: availability of evidence supporting the claim, clarity of its wording and of its scope, transparency of comparisons, and verifiability of environmental statements. It is the same methodology used in the reports, which expressly distinguishes between claims prohibited per se, indicators of potential misleadingness, and assessments based on the available evidence.
The matter becomes particularly relevant from 27 September 2026, the date from which Member States must apply the provisions adopted to transpose Directive 2024/825, which strengthens consumer protection against unfair commercial practices linked to the green transition. (Eur-Lex)
A risk spread across the main European markets
The study examines the ten largest listed companies by market capitalisation in each of the five markets considered, analysing the claims published on their corporate sustainability pages.
The results show considerable uniformity across the four EU countries. The average risk score, on a scale from 0 to 100 where a higher value indicates greater risk, is 53.6 in Spain, 53.0 in Italy, 53.0 in Germany and 52.4 in France. The United Kingdom, used as a European benchmark although it is not subject to transposition of the EU directive, records 53.9.
More significant still is the figure for individual claims: 2,046 of the 2,233 examined, about 92%, trigger at least one indicator of potential misleadingness provided for by the model. In 304 cases, moreover, the screening did not find, in the company pages analysed, evidence sufficient to fully support the statement; five claims are in conflict with external evidence according to the model's assessment, and four trigger a category classified as a breach per se. These categories are not equivalent to one another and must not be interpreted as that many established breaches.
The main problem: saying “green” is not enough, it has to be demonstrable
What emerges from the analysis above all is a problem that cuts across the board: the distance between what a company communicates and how easily a consumer can verify the evidence on which that communication rests.
In all five markets the dominant issue is the lack of accessible documentation supporting the claim (substantiation not accessible). Next come environmental wordings that are unclear or ambiguous, failure to delimit the scope the statement refers to, comparisons without a sufficiently explicit methodology and, in some cases, statements about future environmental performance that are not adequately supported.
The point, therefore, is not only about manifestly incorrect environmental statements. Under the new regulatory framework, even potentially well-founded claims can generate exposure if the evidence supporting them is not easily accessible, if their meaning is ambiguous, or if it is not stated with sufficient precision which product, activity or scope they refer to.
For companies this progressively turns sustainability from a mainly reputational topic into a question that involves compliance, marketing, communication and risk management at the same time.
Reputation Index: measuring risk before it becomes a problem
Integrity Monitor develops an intelligence platform drawing on public and professional sources for assessing the integrity of companies and supply chains. Within the platform, Reputation Index makes it possible, among other functions, to screen environmental and social claims against the criteria introduced by Directive (EU) 2024/825, checking both the presence of specific regulatory indicators and the level of documentary support available. The system assigns a risk index from 0 to 100 and applies a precautionary principle: where the evidence is not sufficient to make an assessment, the claim is excluded from the score rather than penalised.