Legal ESG

Enforcement & Greenwashing

Senken / Max Planck: 68% of DAX40 Carbon Credits Had No Real Climate Impact — €8M+ Average Cost Per Greenwashing Case

Senken's July 13 analysis of corporate greenwashing risk in carbon credit markets — citing Max Planck Institute research — found that more than 68% of DAX40 companies that purchased carbon credits ended up supporting projects with no real climate impact. The Max Planck Institute separately found that 84% of carbon credits across the broader market are high-risk. The enforcement consequence is alre

BY FRONTIER DESK · JULY 17, 2026 · 1 MIN READ

Senken's July 13 analysis of corporate greenwashing risk in carbon credit markets — citing Max Planck Institute research — found that more than 68% of DAX40 companies that purchased carbon credits ended up supporting projects with no real climate impact. The Max Planck Institute separately found that 84% of carbon credits across the broader market are high-risk. The enforcement consequence is already materializing: the average cost per greenwashing case for German companies is now €8 million or more, a figure that substantially exceeds the cost of pre-purchase due diligence on carbon credit quality. For ESG practice leaders and in-house sustainability counsel advising clients on carbon credit strategies, the Senken data is an operational risk quantification: firms that purchase carbon credits without conducting quality due diligence — assessing additionality, permanence, verification methodology, and project-level integrity — are, on the current market evidence, more likely than not to be holding credits that do not represent real climate impact. The legal exposure flows from the claims built on those credits: a "carbon neutral" or "net zero" assertion backed by high-risk credits is the factual basis for the greenwashing liability the French courts imposed on Volvic this week.

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