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Wrapping up 2022 and welcoming 2023

The Green & Sustainable Hub (GSH) is delighted to present its best wishes for 2023 and takes the opportunity to draw lessons from 2022.

Before starting the new year, we looked back on the most important milestones within the green and sustainable finance landscape.

2022 was not only rich in terms of incoming regulation but also densely packed with ambivalent market developments, inflation spiral fed by geopolitical shocks. Taking a step back and pause, to identify driversconstraints, and trends.

We finally identified 4 major developments:

      1. A tangible eruption of greenwashing beyond reputational scandals and risks;

      2. A global regulatory push in sustainable finance outside Europe;

      3. International progress on biodiversity and shift from wishful thinking to actual                tools;

      4. Sustainable finance sensitivity to adverse market developments and geopolitics

We’ll stay on the watch to follow the evolution of these trends into 2023. In the meantime, we wish you a pleasant year and even better read-through.


Natixis CIB Green & Sustainable Hub


1. A tangible eruption of greenwashing in finance beyond reputational risks

From mere reputational risks to litigations and financial regulators’ crack down

“Sustainability” kept gaining traction. Yet, it has simultaneously caused deceit and a concrete rise in greenwashing scandals, probes and lawsuits. Misrepresentation or misleading statements are not newborn tendencies nor are reputational risks, but greenwashing litigations and accusations are very new and becoming real (HSBC advertising posters removal, Goldman Sachs AM settlement with the SEC[1]).

Prompted by increasing greenwashing allegations, a broader consensus has emerged amongst regulators, arguing that vague terms used by funds to market themselves as “green” need to be pinned down and precisely defined. Opaque methodologies or obscure sustainability criteria weighting to inflate sustainable assets amounts are also under scrutiny. As such, financial watchdogs have been honing disclosure requirements and launched search warrants or raids.

A telling illustration of this is the Securities and Exchange Commission (SEC)’s current “war on greenwashing” in the United States. The regulator published disclosure rules in May 2022, designed to integrate ESG dimensions within investment products and thereby repress misleading claims made by ESG funds managers (see our article here). As stated by Commissioner M. Peirce “a key impetus for today’s rule making is a legitimate concern about the practice of greenwashing by investment advisers and investment companies.”[2]

In the UK, the Financial Conduct Authority (FCA), has published a consultation in October to propose new restrictions on investment managers using “ESG” or “green” labels with 3 fund labels to distinguish different types of “sustainable” investments; those labels are mirroring the European Article 8 and 9 fund classification. Funds regulated by the FCA will be given a year to comply once the rule is brought into force in 2023.

In the EU, a clarification on the definition of the term “sustainable” is eagerly awaited under the Sustainable Finance Disclosure Regulation (SFDR) for 2023. Financial sector was indeed deeply mobilized on its implementation but struggled to use harmonized definition of sustainability, whereas in the first place the regulation aimed at fighting the greenwashing risk. 

In Australia, the Competition & Consumer Commission (ACCC) announced to increase scrutiny on green marketing in Sep 2022. Additional disclosure requirements on sustainability marketing and terminology were added into Corporation Act. The authorities launched consultation on mandatory climate-related financial disclosures for large listed companies and financial institutions in Dec 2022. In Hong Kong, the Fund Manager Code of Conduct was amended to mandate TCFD-aligned climate reporting from fund managers in 2022.

With financial regulators toughening their stand and whistleblowers increasingly holding firms accountable, a system of “checks and balances” made of innovation, reputational and legal streams is progressively seeing the day. It imposes some self-restrain from market participants and encourages consistency and proportionality between labels, adds and products or practices. Conversely, sometimes arbitrary accusations and legal insecurity can stymie climate action and lead to “greenhushing” (eco-silent). To address and prevent this growing greenwashing risk, 2022 has witnessed different initiatives arising from market actors or regulators. For instance, the International Capital Market Association (ICAM)’s work on SLB KPI registry to discipline SLB issuances (see our article here) should help enhancing clarity and integrity on the market. The European Securities and Markets Authority (ESMA)’s work on ESG rating agencies to better grasp the structure and the data provided, or its very recent consultation on funds’ names using ESG or sustainability-related terms also aim at supervising the greenwashing risk.

2. A global regulatory push in sustainable finance outside Europe

A regulatory drive across the globe, testifying of actors’ ambition to go beyond mere disclosure and sustainable finance’s internationalization

The EU has walked the talk on regulations and climate-policy.

Benefiting from its first mover advantage, the EU has reaffirmed its green policy pioneer position. On the regulation side, 2022 began with the Delegated Act of the Taxonomy Regulation Article 8’s entry into force, requiring financial and non-financial companies to provide further information to investors about assets’ environmental performance, to increase transparency[3]. The European Supervisory Authorities (ESA) brought further clarification on their Regulatory Technical Standards draft, under the SFDR, in April 2022 : details were specified for the content and presentation of information related to the “Do no significant harm” (DNSH) principle as well as information’s presentation linked to sustainable investment objectives’ mentioned in pre-contractual documents, websites and periodic reports[4].

Beyond disclosures clarification, the EU pursued new climate-related actions on all fronts, on the policy side with the European Green deal and fit-for 55 package led by the Commission, but also on the monetary side, with the ECB’s climate-change actions entering into force (See our article “ECB to decarbonize its corporate bond purchasing and collateral framework from intent to almost immediate action”, available here).

The ECB instilled new measures to introduce climate change considerations in its monetary framework, by gradually tilting its holdings towards issuers with “better climate performance”, “measured with reference to lower greenhouse gas emissions, more ambitious carbon reduction targets and better climate related disclosures[5]”.

Amongst the “Fit for 55” initiatives figure the Carbon Border Adjustment Mechanism (CBAM) and the EU Emissions Trading System (EU ETS) reforms (See our article here). Furthermore, the European parliament voted to ban the sales of new internal combustion engines within the EU from 2035 onwards, to cut carbon-dioxide emissions[6].

Against a backdrop of fuel poverty caused by inflation, the social disruptions which can be caused by a faster transition caught stakeholders’ attention. All these new climate policies justified the creation of a Social Climate Fund, dedicated to a fair transition and established to specifically address “the social and distributional impacts on the most vulnerable arising from the emissions trading of buildings and road transport”[7]. The environmental transition’s social dimension has therefore been tackled this year and the terms “fair” or “just transition” have become increasingly adopted and debated, especially during the COP27.

Meanwhile in the United-States, the publication of the Inflation Reduction Act including $369 billion in funding to tackle climate change marked the year 2022. The Securities and Exchange Commission (SEC) also has taken up the subject in climate-disclosure matters. It proposed both new climate-related disclosure requirements for public companies [8] as part of the issuer rule, and rules to enhance disclosures by investment advisers and companies about ESG investment practices [9]. These should bring enhanced transparency on the market, while the SEC proposal for rule changes to prevent misleading or deceptive fund names [10] should help to fight against misleading marketing practices.

However, these new regulatory developments are by no circumstances solely limited to the US and Europe.

On the contrary, and for instance, five new taxonomies were published throughout the year across the globe (in order: Indonesia, South Africa, Colombia, Sri Lanka and Georgia). Singapore Green Finance Industry Taskforce (GFIT) published the version 2 of Green and Transition Taxonomy for public consultation, while Singapore Ministry of Finance (MoF) published the Green Bond Framework in June 2022 to allow easier access to green project financing. Conversely, in Europe, there is a bit of fatigue. The European Commission’s decision regarding its own taxonomy’s potential extension and the creation of a social taxonomy is awaited for 2023 (See our article “Extended Taxonomy: acknowledging in betweenness to soften elitism”, available here, EU Social Taxonomy Proposal : simpler and meaningful but half-way through, available here) [11]. With the forthcoming European Elections in 2024, we do not expect major foray and initiative.

Whilst a ‘global’ taxonomy will probably not see the day soon, these frameworks use commonly shared principles (for instance the ‘DNSH’ principle, science-based criteria). Their adoption, publication and drafting have sparked discussions on greater alignment across markets, leading to cooperation on a “Common Ground Taxonomy”, released in June 2022. (See our article ‘Updated Common Ground Taxonomy’, available here). We can expect greater standardization and metric mainstreaming for the coming years, across countries.

3. International progress on biodiversity and shift from wishful thinking to actual tools

2022’s international negotiations and the advent of biodiversity: from theory to an international political agreement and the mainstreaming of metrics

Despite ambivalent results and controversies, the COP27 also reached another key agreement for the sustainable finance landscape, the creation of a Loss and Damage Fund that aims to provide financial assistance to nations left most vulnerable to the impacts of climate change. 2023 only will tell how the fund will be operationalized, with what precise means and for whom, to enable a “fair transition”.

On a global scale, 2022 marked a watershed for biodiversity. Regrouping representatives of over 188 governments, the COP15 resulted with the adoption of the Kunming-Montreal Global Biodiversity Framework (GBF), which includes a target to protect 30% of Earth’s lands, oceans, coastal areas and inland waters by 2030.

To go in further details, read our article “Climate is dead, long live biodiversity… COP15, a kick-start to biodiversity mainstreaming” available here.

4. Sustainable finance sensitivity to adverse market developments and geopolitics

Sustainable finance has not remained impermeable to adverse market developments and geopolitical dynamics. Indeed, the “sector” being critically exposed to energy-price fluctuations, the war in Ukraine affected, if not reshaped, investors and governments’ sustainable finance practices alike in the long and short term.

On the short term, previously avoided high carbon-emitting sectors became attractive financially. Markets participants witnessed a change in the equation: whilst demand for sustainable stock dwindled on the one hand, increasing energy needs and security fears bolstered the appeal of oil & gas sectors on the other.

For instance, equity ESG funds saw a 60% inflow slowdown to $9.4 billion in March, compared with inflows of $24.4 billion in the prior April. Unexpectedly, vanilla stocks and bonds were outperforming the socially responsible ones[12].

On the long term, the Ukraine war has accelerated the clean energy transition. Energy supply fears have paradoxically played both for and against sustainable finance. By prompting a race for countries to strengthen their energy security, governments have added policy weight to renewable energy investment programs, to limit their reliance on imported fossil fuels – a telling illustration is the RePower EU plan. An IEA report highlights that global renewable power capacity is expected to grow by 2400 gigawatts over 2022-2026, either the entire power capacity of China and 30% higher than originally forecasted growth amount[13]. This conflict marked a clear watershed in the development of domestically produced renewable energy.

Beyond market trends, the war profoundly altered ESG investors’ behaviors altogether when it comes to country risks and exposure, by highlighting the shortcomings of ESG data or “ESG-washing trends” on the matter. If several specialized ESG research houses downgraded Russia on the “G” and “S” dimension after the invasion’s start; it did not anticipate geopolitical fault lines. Ratings methodologies have therefore been questioned and scrutinized: do they sufficiently incorporate political risks, autocracy risks, measures on human freedom, risk of international sanctions ? How did they “miss”? Financial actors might increasingly rely on complementary political risk data in 2023, with heightened imperatives for human rights due diligence to identify and mitigate risks. Geopolitics and green finance might become more closely intertwined in the next years, equally important concerns such as strategic autonomy, inequalities narrowing, decarbonization and biodiversity protection will have to be married.

With these trends set in action, 2023 has several promises to deliver on and multiple obstacles to overcome. At Natixis, we’ll be on the look-out for the EU’s publication on the technical screening criteria for the 4 non-climate environmental objectives, the UK’s taxonomy’s drafting advances, the ECB’s additional actions to strengthen its green monetary policy and much more… We will continue to accompany client transition, frame our products to further include sustainability and develop advisory solutions for tailor-made strategic approach. We’ll be wary of greenwashing, remain critical and analytical in our endeavors, refine and try to operationalize our understanding of climate adaptation, carbon credits, biodiversity, and their subsequent metrics and related financial products.

In the meanwhile, we wish you a pleasant year ahead and look forward to working with you, navigating the sustainable finance landscape one step at a time.

2022 was the year of


A year of many “first”

On the supply side:

Main market figures and trends:

  • Stable ESG financing penetration rate in 2022 compared with 2021, with 27% of euro bonds and 23% of loans on EMEA market including ESG features, despite 30% drop of supply in ESG labelled debt due to credit markets backdrop
  • Green/social use of proceeds formats still the leading format on the bond market, compared with SLB still lagging behind with market scrutiny

Main innovation in terms new product frontiers:

  • Publication of Nordea SLL Funding Bond framework
  • Nexans Green ESOP
  • Ramsay sustainability-linked trust facility
  • Alstom sustainability-linked syndicated guarantee facility
  • The first 3 SLB issued by SSA (Chile, Uruguay, and Ghana), with Uruguay issuance being the first to include a coupon step-down if it overperforms on the pre-defined KPI and a forest area indicator as a biodiversity KPI

On the demand side:

  • Increased number of Social Bond Funds with 10 Investors managing 12 Funds, among which 4 launched in 2022 
  • Launch of several biodiversity/ natural capital funds, but mainly on the equity side

Landscape of actors

  • Continuous market consolidation in sustainability businesses: CICERO acquired by S&P, Icare acquired by Bearing point, Ecovadis record capital increase, Quantis acquired by BCG


Disclosure, taxonomies & classifications

Entry into force and/or first publications:

  • First disclosure of financial and non-financial companies' eligibility to the European Taxonomies (Article 8)
  • First disclosure of Sustainable investment definition and methodology (under SFDR) by Financial Markets participants, asset managers in particular
  • First disclosure of the French Energy-Climate Law Article 29 requirements by financial market participants
  • Entry into force of the revised MiFID 2 Directive requiring addressing ESG elements in all relationship between financial advisors and end investors
  • Beyond European regulators, US SEC targets greenwashing with New ESG fund disclosure Rules

Newly adopted or voted

  • Adoption of the complementary Delegated Act on nuclear and gas
  • Adoption of the CSRD final text, as well as submission of the European Sustainable Reporting Standard (ESRS) to the Commission by the EFRAG
  • Adoption of the EU Commission’s proposal for a Regulation to “minimize EU-driven deforestation and forest degradation”.

Guidance, reports, debates or negotiations

  • Platform on sustainable finance recommendation for the drafting of the 4 remaining taxonomy environmental objectives
  • Ongoing negotiations on the European Green Bond Standard
  • New guidance by the EU Sustainable Platform on taxonomy data and usability, and minimum safeguards
  • Publication of the Platform’s report on Social Taxonomy but no political willingness to enshrine it into law
  • Platform’s recommendations on extending the Taxonomy to amber and red activities

Supervision, monetary and prudential policies

  • EU markets regulator kicks off process to regulate ESG ratings
  • ECB thematic review to conclude there are blind spots at 96% of European banks in their identification of climate-related and environmental risks
  • Increased scrutiny of green claims leading to an increase in legal cases, with lawsuits (new companies face class action lawsuits, including Whole Foods, KLM)
  • ECB started to tilt its corporate bond purchases towards issuers with better climate performances (“Green QE”)

Market observation

  • Increase of the market share of Article 8 and Article 9 fund assets to reach 53.5% at the end of September 2022
  • In Europe, Article 9 SFDR funds reclassification in fear of greenwashing risks. 1,500 funds are at risk of losing their article 9 status due to green investment level according to FE Fundinfo.


Biodiversity & nature capital policies or initiatives

  • COP 15 historical agreement: target to protect 30% of Earth’s lands, oceans, coastal areas, inland waters by 2030
  • Investor group (including AXA IM, BNP Paribas AM, Robeco among others) launches Initiative to engage companies on biodiversity and nature loss at the Cop15. This initiative is called Nature Action 100.

Climate policies or initiatives

  • Publication of the Inflation Reduction Act in the US including $369 billion in funding to tackle climate change
  • First NZBA interim targets for banks (GFANZ)
  • Cop 27 (Establishment of the Loss & damage fund, launch of “Global Shield Against Climate risks”, increased recognition of the strong link between forest/nature and climate change.
  • EU Political agreement on the introduction of a carbon border tax and the progressive phasing out of EU-ETS free carbon allowances
  • ISSB Climate Reporting Standard drafted by the IFRS Foundation
  • UN High Level Expert Group launched a report to ensure credible and accountable net zero pledges from non-state entities
  • Texas places BlackRock, Credit Suisse & UBS on Divestment List for “Boycotting” fossil fuel Companies in Anti-ESG Backlash

Sustainable finance initiatives

  • Debates on SLB lack of integrity
  • ICMA published further guidance on SLBs, including 300 KPIs covering 22 sectors
  • ICMA’s Repo & Sustainability Taskforce’s paper on categorisations relating to sustainability in the repo market.
  • ICMA Sustainable Securitisation Q&A release
  • CBI to expand its Climate Bonds Standard to certify SLBs and corporate entities

Fair transition evolution & initiatives

  • Growing integration of Just, Fair, and Inclusive transition by investors.
  • Social concerns keep rising on their agenda with Ukraine invasion, esp. fuel poverty
  • New policy and market initiatives on fair transition as well as loss and damages (N/S, private investors)
  • Creation of a Social Climate Fund to compensate for the creation of an EU emissions trading system for building and transport sectors

ESG thematic evolution and initiatives

  • Launch by the ELFA of an ESG diligence questionnaire for CLO managers
  • Investor-led ESG initiatives for private debt investments “ESG Integrated Disclosure Project” (promotes transparency and consistency of ESG disclosure by borrowers in private credit and syndicated loan transactions) and “ESG Covenant Package” (for infrastructure debt financings)
  • ESMA published results on its call for evidence on ESG ratings (in which “most respondents highlighted some degree of shortcoming in their interactions with the rating provides, most notably on the level of transparency as to the basis for the rating”
  • In November 2022, the European Supervisory Authorities (ESAs) launched a call for evidence on greenwashing.
  • In December 2022, the ESMA launched a consultation on ESG and sustainability-related terms in funds names to fight against greenwashing.



  • SBTi guidance for Forest, Land and Agriculture (FLAG) method for companies in land-intensive sectors
  • TNFD published 4 pilot nature scenarios and its beta framework v3.0 for market participants to disclose their ‘impacts’ and ‘dependencies’ associated with nature


  • SBTi methodology for financial institutions
  • IPCC’s second part of the sixth assessment reports (AR6) on impacts, adaptation and vulnerability and Mitigation
  • New initiatives aimed at instilling further discipline on the use and development of carbon credits (ICVCM, VCMI)

Sustainable finance

  • ICMA KPI Registry for SLB and Mapping of carbon target setting/assessment methodologies (Read our article here)

2023 will be the year of


Expected for the supply

  • SLB diversification in terms of sector, incl. airlines, steel industry
  • Further development of SLB market’s SSA segment
  • Supply on the Social Bond segment could decrease down to Eur 45-50bn

General market & trend evolution

  • Greater ESG integration in private debt markets
  • Green & Sustainable savings/deposit accounts
  • ESG employee stock ownership plans
  • Sustainable Trade finance & supply chain solutions

Product expected evolutions

  • Green & Sustainable Monetary instruments: CPs, Repo, etc.


Regulatory disclosure or risk management

  • EU Taxonomy alignment mapping to be disclosed for non-financial companies
  • Next phase SFDR regarding reporting under level 2 regulation package
  • Under French Energy and Climate law, entry into force of the interdiction to promote carbon neutrality of a product if not explicitly proven
  • 1st CRR3 Pillar 3 ESG reporting for Banks
  • Banks must include climate and environmental risks in governance, strategy and risk management by the end of the year
  • Transition plans disclosure to be increasingly integrated into regulatory framework

Expected to be adopted, voted or decided

  • Publication of the drafts regarding the technical screening criteria for the 4 non-climate environmental objectives 
  • Adoption of the Regulation on the EU Green Bond Standard
  • Adoption of the Sustainability Disclosure Requirements (SDR) and investment labels in the UK
  • Formal decision from the EU on a potential Social Taxonomy extension
  • Formal decision from the EU on extending the Environmental Taxonomy (amber, red, etc.)
  • ECB to take additional actions to green its monetary policy, as exposed by Isabel Schnabel on 10 January 2023

Expected guidance or report

  • Clarification on Sustainable definition (for more consistency in the market and prevent greenwashing) under SFDR, and ESMA’s recommendations on greenwashing

Supervision, monetary and prudential policies

  • The EBA to publish a report on prudential treatment of banks’ exposure to climate risks in June 2023, especially their integration within pillar 1

Market expectations

  • Increase of greenwashing litigation cases and greenhiding phenomenon



  • Natural capital / biodiversity: the first version of science-based Target for Nature guideline is set to be published early 2023


  • Carbon Border Adjustment Mechanism (CBAM) transitional period to start as of 1st October 2023
  • COP28 in Dubai

Sustainable finance

  • Adaptation finance take-off
  • Transition plans / potential

Social & SDGs

  • Just transition to be increasingly integrated to environmental / ecological debates
  • The 2023 SDG Summit at Head of States/government levels to follow-up and review the implementation of the 2030 Agenda


  • Expected implementation of climate-related disclosure standards by the ISSB in 2023
  • ESG Data & Net Zero methods & tools
  • ISSB’s new international sustainability disclosures standard to be published in 2023.
  • SBTN to finalize first release of SBTs for nature (v1) in early 2023 to complement SBTi methodology


[1] For instance:

  • In 2022, the British advertising authority forbade HSBC to use advertising posters deemed “misleading” after several complaints against two posters that ignored important information about the bank’s contribution to greenhouse gas emissions.
  • On 22 November 2022, the SEC charged Goldman Sachs Asset Management (GSAM) for policies and procedures failures involving two mutual funds marketed as ESG investments. GSAM agreed to pay USD 4 million to settle the charges.

[2] Statement on Environmental, Social and Governance Disclosures for Investment Advisers and Investment Companies, Commissioner Hester M. Peirce, May 25 2022.

[3]Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021, supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council, Official Journal of the European Union.

[4]Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Councill, Official Journal of the European Union.

[5] Press Release, European Central Bank, “ECB takes further steps to incorporate climate change into its monetary policy operations”, 4 July 2022.

[6] Union européenne : vers l'interdiction de voitures neuves à moteur thermique dès 2035, Vie Publique, 29 Juin 2022.

[7] European Commission, Proposal for a Regulation of the European Parliament and of the council, establishing a social climate fund, Brussels, July 2021.

[8] SEC, SEC Proposes Rules to Enhance and Standardize Climate-Related Disclosures for Investors, March 2021.

[9] SEC, SEC Proposes to Enhance Disclosures by Certain Investment Advisers and Investment Companies About ESG Investment Practices, May 2022.

[10] SEC, SEC Proposes Rule Changes to Prevent Misleading or Deceptive Fund Names, May 2022.

[11] EU extended Taxonomy for sustainable activities: Final Report on Taxonomy extension options supporting a sustainable transition, 2022, available here. Final Report on Social Taxonomy, Platform on Sustainable Finance, February 2022.

[12] Greifeld, Katherine, The ESG Crown Is Slipping, and It’s Mostly the Fund Industry’s Own Fault, 2nd of September 2022, Bloomberg.

[13] Renewable power’s growth is being turbocharged as countries seek to strengthen energy security, IEA, 6th of December 2022.