Greenwashing gems: How asset managers play with regulation

Since May 2025, the European Securities and Markets Authority (ESMA) has set minimum criteria for funds that use ESG-related terms in their names [1]. Yet some asset managers are finding ways to exploit loopholes in the rules and retain names with a sustainable connotation while investing in fossil fuel developers. Reclaim Finance identifies several emblematic cases of this well-worn practice and calls on the European Commission to require the exclusion of companies developing new fossil fuel projects from all ESG-labelled funds.

Adding a simple ESG-related term allows a fund to attract more capital by influencing savers’ choices [2] — an advantage asset managers are eager to seize, as shown by several Reclaim Finance analyses exposing the continued exposure of “green” funds to companies developing new fossil fuel projects [3]. To limit such practices, ESMA has published guidelines governing fund naming. The use of terms related to the environment, impact and sustainability in fund names now requires the exclusion of companies heavily involved in fossil fuels from their investments, while those using terms related to transition, social or governance do not.

The art of renaming not to change a thing

Reclaim Finance analyzed 190 funds domiciled in France or managed by a French asset manager that changed their names between May 2024 and May 2025, following the publication of ESMA’s guidelines [4]. Nearly half modified their names to escape certain constraints, while others exploited loopholes in the regulation. Some cases are particularly revealing.

According to our analysis, in August the fund invested in more than a dozen companies developing new oil and gas fields, including ExxonMobil, BP and TotalEnergies.

Initially called Amundi S&P Global Energy Carbon Reduced, the fund was renamed to remove the term “Carbon Reduced.” Yet, Amundi now uses the term “Screened” — not covered by the new regulation — which could suggest a certain level of rigor in how assets and companies are selected.

This is not an isolated case: according to Morningstar, the use of the words “Screened” and “Selection” has surged over the past year, ranking first and fourth among the most frequently added terms to fund names during this period [5].

According to our analysis, in August the fund invested in TotalEnergies.

Formerly called ESG Improvers Europe ESR, this Amundi fund dropped the term “ESG Improvers” which had become more restrictive under ESMA’s new guidelines. It now uses the word “Selection”, vague enough to avoid having to prove that part of its portfolio meets transition requirements.

According to our analysis, in August the fund invested in major national oil companies such as Petrobras, Saudi Aramco, Oil India, Adnoc and Sinopec.

Previously called Amundi MSCI Emerging ESG Broad CTB (Climate Transition Benchmark), the fund remains in the transition category, which does not require the exclusion of fossil fuel companies. Amundi is not using tricks here, but rather exploiting a regulatory loophole: when a fund combines terms linked to environment or impact with those related to transition, only the transition rules apply. This is a notable exception, since in all other cases of combined terms, conditions are cumulative.

For Amundi alone, at least 10 funds combining ESG and transition terms still invest in companies developing new fossil fuel projects while ESMA’s guidelines came into force.

According to our analysis, in August the fund invested in French and Austrian oil and gas multinationals, TotalEnergies and OMV.

Formerly called SICAV European Improvers, the fund should, under that name, have demonstrated social or environmental transition commitments. By replacing “Improvers” with Catalysts, Edmond de Rothschild AM sidesteps ESMA’s these requirements while preserving an attractive image.

According to our analysis, in August the fund invested in Italian oil and gas major Eni.

Previously named Change Convertibles Europe, this Rothschild & Co AM [6] fund would also have been required to provide transparency on the transition pathways of its investee companies. By opting for the word Conviction, the manager frees itself from this constraint.

The art of influencing not to change a thing

The ease with which some asset managers avoid the main constraints of the regulation is no accident: it stems from the influence they exercised during the drafting of the guidelines.

Financial players mobilized in large numbers to respond to ESMA’s 2022 public consultation: Amundi, BNP Paribas Asset Management, UBS, BlackRock, JP Morgan AM… Opposed to the use of Paris Aligned Benchmark (PAB) exclusions — which require divestment from fossil fuel companies — they pushed for much looser criteria, particularly for funds claiming to be “ESG” or “Transition” [7].

BlackRock:

“Investors express their sustainability needs and preferences in a variety of different ways, not all of which involve avoiding certain companies or sectors. Where those preferences do involve avoiding certain types of exposures, investors do not always seek to avoid the same ones, making a uniform set of minimum exclusion criteria across all products with an ESG- or sustainability-related term in their name problematic.”

Amundi:

“As a general comment, we believe that exclusions are not appropriate as minimum safeguards for investment funds. In addition, exclusions generally do not recognize firms that are making efforts to transition.”

With the revision of the SFDR — the EU regulation on sustainability-related fund disclosures — approaching, the same lobbying dynamics are playing out: major financial players are multiplying contributions to defend a similar position, notably calling for fossil fuel–related exclusions to be limited to a single category. This would provide companies developing new fossil fuel projects with safe havens within “ESG”, “responsible”, “transition” or “impact” funds. If the European Commission adopts these proposals, the loopholes already identified in ESMA’s guidelines would be replicated in the SFDR and facilitate greenwashing.

To safeguard the credibility of European sustainable finance, a clear red line must be drawn: no fund claiming to be ESG or transition should be allowed to invest in companies involved in developing new fossil fuel projects [8]. Without this, sustainable finance will remain an empty slogan.

Notes:

  1. Guidelines on funds’ names using ESG or sustainability-related terms”, ESMA, August 2024
  2. Fund names: ESG-related changes and their impact on investment flows”, ESMA, April 2025
  3. 70% of passive funds and employee savings funds, as well as 55% of so-called “green” life insurance funds, invest in companies developing new fossil fuel projects, Reclaim Finance, March – June 2024
  4. Inspired by “From “sustainable” to “screened”: 674 funds bypass climate regulation through targeted renaming”, Urgewald and Finanzwende, May 2025; the analysis is based on a sample of 190 funds domiciled in France or managed by French asset managers, including 86 whose name changes allowed the asset manager to circumvent certain constraints imposed by ESMA’s new rules. To analyze this sample, we cross-checked:
    1. the portfolio composition of these funds provided by Morningstar Data Services and extracted the 11th of August 2025;
    2. the list of companies developing new fossil fuel projects included in the Global Oil & Gas Exit List 2024 and Global Coal Exit List 2024 databases, published annually by the German NGO Urgewald.
    3. Moreover, we did not count green bonds in the fossil fuel exposures mentioned.
  5. ESMA Guidelines on ESG Funds’ Names – Early insights into rebranding activity and portfolio impact”, Morningstar, May 2025
  6. Contacted by Reclaim Finance, Rothschild & Co AM explained that this name change was unrelated to ESMA’s guidelines, but rather corresponded to a decision made when the fund lost its French SRI (Socially Responsible Investment) label. Amundi, for its part, simply stated that it complies with ESMA’s rules.
  7. The responses to ESMA’s public consultation are available here: Consultation on Guidelines on funds’ names using ESG or sustainability-related terms. Among the asset managers cited, all opposed applying Paris-Aligned Benchmark (PAB) exclusions — which require excluding fossil fuel companies — to all funds using ESG or sustainability-related terms. UBS and JP Morgan AM suggested instead applying Climate Transition Benchmark (CTB) exclusions, which do not cover fossil fuel companies. CTB exclusions were ultimately chosen by ESMA for the “transition”, “social” and “governance” categories in the final text.
  8. For more information, see Reclaim Finance’s response to the European Commission’s public consultation: Reclaim Finance Position.

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2025-09-18T16:11:14+02:00