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ESMA Guidelines on funds' names using ESG or sustainability-related terms

EU·guideline·applicable

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Official text
ESMA34-1592494965-657 — Guidelines on funds' names using ESG or sustainability-related terms (ESMA)
Status
applicable — comply-or-explain for national competent authorities
Jurisdiction
EU
Type
guideline (soft law)
This page
summary only — the linked Guidelines are the source

These Guidelines set a plain condition: if a fund puts an ESG or sustainability word in its name, it must actually invest to match — at least 80% of its investments used to meet the environmental or social characteristics or sustainable objectives the name implies — and it must apply a set of exclusions that gets stricter depending on which term it uses. They are ESMA's answer to greenwashing-by-name: the name is a claim, and the Guidelines make the portfolio back it up.

Scope and the core mechanism

The Guidelines apply to fund managers across the EU fund universe — UCITS management companies and AIFMs (including internally managed funds), and the managers of EuVECA, EuSEF, ELTIF and money-market funds. The mechanism has two parts. First, a quantitative threshold: a fund using an ESG or sustainability-related term in its name should invest at least 80% of its investments to meet the environmental or social characteristics, or the sustainable investment objectives, that the name conveys. Second, exclusions calibrated to the term: the stricter Paris-Aligned Benchmark (PAB) exclusions apply to environmental-, impact- and sustainability-type terms, while the lighter Climate Transition Benchmark (CTB) exclusions apply to transition-, social- and governance-type terms. Certain terms carry extra commitments — "sustainable" implies a meaningful allocation to sustainable investments, "transition" implies a measurable path, and "impact" implies investing with the intention of generating a positive, measurable effect.

The gotcha: this is a naming rule, not a disclosure category — it operates independently of a fund's SFDR Article 8 or 9 status. A fund can be fully compliant on its SFDR disclosures and still have to rename or reposition because its name over-promises against the 80% test and the exclusion set.

Key requirements

RequirementWhat it saysThe practical point
80% investment thresholdAt least 80% of investments used to meet the E/S characteristics or sustainable objectives implied by the nameThe name sets the floor — you cannot label a fund on a strategy that is a minority of the book
Environmental / impact / "sustainability" termsApply the Paris-Aligned Benchmark exclusions (the stricter set, including fossil-fuel activity thresholds)The heaviest exclusions attach to the greenest-sounding names — a fossil-fuel holding can be disqualifying
Transition / social / governance termsApply the Climate Transition Benchmark exclusions (controversial weapons, tobacco, serious international-norms violators)A lighter but real exclusion floor — "transition" is not a free pass on the worst names
"Sustainable" termsCommit to invest meaningfully in sustainable investments within the meaning of SFDRThe word "sustainable" carries an extra allocation commitment beyond the 80% and exclusions
"Transition" and "impact" termsInvestments on a measurable transition path ("transition"); made with intention to generate positive, measurable impact ("impact")These terms import an intentionality/measurement standard — assert it and you must be able to evidence it
Combined termsWhere a name combines categories, the applicable exclusions and commitments stackMixing "sustainable transition" pulls in the stricter of the two — read the name as the sum of its claims

Status and timeline

DateInstrumentWhat changed
2024Final Guidelines published (ESMA34-1592494965-657)Set the 80% threshold, the PAB/CTB exclusion split and the per-term commitments; became applicable following translation into all EU languages, with a transitional period for funds existing before the application date

What it works with

The Guidelines bite on funds run under the UCITS Directive and AIFMD, and on the EU labelled products — EuVECA, EuSEF and the ELTIF. Their nearest analogue outside the EU is the UK's naming-and-marketing regime under the FCA ESG sourcebook (SDR) — the two solve the same greenwashing-by-name problem with different mechanics, and a manager marketing on both sides of the Channel has to clear both.

The gotcha: the fastest place to fall foul of ESG rules is the fund's name, because it is fixed early and expensive to change. Test the name against the 80% threshold and the exclusion set before it is registered — a rename after launch means investor notices, document changes and reputational noise.

To verify

  • Application and transitional dates — pin the exact application date and the length of the transitional period for pre-existing funds against the ESMA text and the national competent authority's confirmation.
  • Exclusion cross-references — confirm the current PAB and CTB exclusion articles (Commission Delegated Regulation on climate benchmarks) that the Guidelines incorporate before applying them to a portfolio.
  • Term categorisation — where a name uses an unusual or combined term, confirm which category (and therefore which exclusions) ESMA and the home authority treat it as falling into.

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