Greenwashing risk is fragmenting across regulators, labels and litigation theories

A&O Shearman’s 2026 greenwashing update tracks UK and EU regulatory initiatives, ESMA work on ESG-related fund names, and UK ASA and CMA activity alongside litigation and enforcement risk. The key point for counsel is that rollback and simplification do not remove greenwashing risk; they make evidence, consistency and jurisdiction-specific claim controls more important.