--- title: "Greenwashing in India: Laws, Regulations and Compliance Risks for Businesses " date: 2026-08-12 author: "Aurelia Menezes" url: https://ksandk.com/energy/greenwashing-in-india-laws-regulations-compliance-risks/ --- # Greenwashing in India: Laws, Regulations and Compliance Risks for Businesses  Posted On - 12 August, 2026 • By - Aurelia Menezes ![Greenwashing in India showing eco-friendly branding contrasted with industrial pollution, environmental compliance and sustainability claims.](https://ksandk.com/wp-content/uploads/ChatGPT-Image-Aug-12-2026-06_04_06-PM-1.png) ## Introduction Environmental, Social and Governance (“ESG”) considerations have increasingly become an important component of corporate decision-making, investor assessments and brand positioning in India. As businesses seek to demonstrate their environmental credentials, terms such as “green”, “eco-friendly”, “sustainable”, “carbon neutral” and “environmentally friendly” are increasingly used in advertising, product packaging, corporate communications and sustainability disclosures.  The growing commercial value attached to environmental claims has, however, also increased the risk of greenwashing i.e. the practice of making misleading, deceptive, exaggerated or inadequately substantiated claims regarding the environmental benefits of a product, service or business.  In India, greenwashing is not governed by a single, standalone statute. Instead, the regulatory framework has developed across consumer protection law, advertising self-regulation, securities regulation and ESG disclosure requirements. The Central Consumer Protection Authority (“CCPA”) has issued specific guidelines addressing greenwashing and misleading environmental claims, while the Advertising Standards Council of India (“ASCI”) has established requirements governing environmental claims in advertisements. The Securities and Exchange Board of India (“SEBI”) has also introduced requirements addressing greenwashing in the context of green debt securities and ESG-related disclosures.  For businesses, the increasing regulatory focus means that environmental claims can no longer be viewed solely as a matter of marketing or reputation. Depending on the nature of the claim and the audience to whom it is made, misleading environmental representations may give rise to consumer protection, advertising, securities-law and corporate compliance concerns.  This article examines the regulatory framework governing greenwashing in India and highlights the principal compliance risks for businesses making environmental and ESG-related claims.  ## Understanding Greenwashing and ESG Misrepresentation Greenwashing generally refers to the practice of creating a misleading perception regarding the environmental benefits or credentials of a product, service, process or company. Greenwashing may take several forms, including:  - using broad or ambiguous terms such as “green”, “clean”, “natural”, “eco-friendly” or “sustainable” without adequate substantiation;  - selectively disclosing favourable environmental data while omitting material information that may present a less favourable picture;  - using environmental imagery, colours or symbols in a manner that creates a misleading impression about the environmental characteristics of a product or service;  - making carbon-neutral, net-zero or carbon-offset claims without adequate evidence or a credible basis for the claim; and  - making comparative environmental claims without clearly identifying the basis of comparison.  The CCPA’s Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024 (“CCPA Guidelines”) specifically address misleading environmental claims made in relation to goods and services. The Guidelines define “greenwashing” broadly to include misleading or deceptive practices involving the concealment, omission or misrepresentation of relevant information, as well as the use of misleading words, symbols or other forms of expression that highlight environmental benefits while downplaying environmental harm.  An “environmental claim” is similarly broad and includes representations concerning the environmental friendliness of a good or service, including aspects relating to its components, manufacture, use, packaging, storage and disposal.  The Guidelines also recognise that not every general statement about environmental philosophy will necessarily amount to greenwashing. Generic statements, hyperbole or puffery, and certain uses of colours or imagery, are not prohibited merely because they have an environmental association. The issue arises where the overall representation is misleading or deceptive, or where the statement is connected with a specific good or service in a manner that creates a misleading environmental impression.  ### **Greenwashing and ESG Misrepresentation** Greenwashing and ESG misrepresentation are related but distinct concepts. Greenwashing generally concerns misleading representations about environmental benefits or credentials, particularly in consumer-facing communications. ESG misrepresentation is potentially broader and may involve inaccurate, incomplete or misleading information relating to environmental, social or governance matters provided to investors, regulators or other stakeholders.  For example, an environmental claim made in an advertisement may primarily raise issues under consumer protection and advertising rules. In contrast, an inaccurate ESG disclosure made by a listed entity in a regulatory filing or sustainability report may raise separate securities-law and disclosure concerns.  The distinction is important because the applicable regulatory requirements and potential consequences may differ depending on the nature of the representation, the person to whom it is made and the regulatory framework governing that communication.  ## The Regulatory Framework Governing Greenwashing in India India currently does not have a single anti-greenwashing legislation. Instead, several regulatory and self-regulatory frameworks address different aspects of environmental claims and ESG disclosures.  #### **(a) CCPA Guidelines on Greenwashing and Misleading Environmental Claims, 2024** The CCPA issued the Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024 under the Consumer Protection Act, 2019. The Guidelines seek to ensure that environmental claims made by businesses are truthful, accurate, capable of substantiation and not misleading to consumers. They apply to environmental claims made in advertisements and communications concerning goods and services covered by the Guidelines.  Among other things, the Guidelines require environmental claims to be supported by adequate and credible evidence. Businesses making specific environmental claims must ensure that the basis for such claims is adequately disclosed and that consumers are not likely to be misled by the manner in which the claim is presented. Relevant information supporting a claim may, where appropriate, be made available through mechanisms such as QR codes or web links.  The Guidelines also address the use of broad environmental terminology and require businesses to provide sufficient context and qualification where necessary. Claims based on scientific studies, research or data should not selectively present favourable information while concealing material information that could alter the overall impression created by the claim.  The CCPA framework is therefore particularly relevant to businesses making environmental representations in consumer-facing advertisements, product descriptions, packaging and other marketing communications.  #### **(b) ASCI Guidelines for Advertisements Making Environmental/Green Claims, 2024** The Advertising Standards Council of India (“ASCI”) has also established specific guidelines governing environmental or green claims in advertisements. ASCI is an advertising industry self-regulatory body rather than a statutory regulator. Its guidelines supplement the broader consumer protection framework and provide advertisers with standards for making environmental claims.  The ASCI framework addresses several categories of environmental claims, including absolute and comparative claims, claims relating to the entire lifecycle of a product, future environmental objectives, carbon-offset claims and claims involving certification or environmental credentials. For example, forward-looking environmental claims should be supported by a clear and actionable plan demonstrating how the stated objective is intended to be achieved. Similarly, environmental imagery or symbols should not create an impression of environmental benefit where the underlying claim cannot be substantiated.  Businesses therefore need to consider both the CCPA Guidelines and ASCI requirements when developing advertising campaigns containing environmental claims.  #### **(c) SEBI Framework for Green Debt Securities and ESG Disclosures** Greenwashing risks also arise in the securities market, particularly where companies raise capital through instruments marketed as “green”. SEBI’s framework governing green debt securities contains requirements intended to reduce the risk of greenwashing. These include requirements relating to the use and monitoring of proceeds, disclosure, reporting and the manner in which green debt securities are represented to investors.  SEBI has also specifically identified practices that may amount to greenwashing, including misleading labelling, selective disclosure of favourable environmental information, misleading claims regarding third-party certification and representations that are not adequately supported by the relevant underlying information. The regulatory framework has subsequently developed beyond green debt securities, with SEBI introducing a framework for Environmental, Social and Governance (“ESG”) debt securities other than [green debt securities](https://ksandk.com/energy/india-uk-fta-green-economy/).  Accordingly, businesses raising capital through ESG-linked or environmentally focused securities must ensure that their representations to investors are consistent with the applicable SEBI requirements and are supported by appropriate documentation and verification.  #### **(d) Business Responsibility and Sustainability Reporting** SEBI’s Business Responsibility and [Sustainability Reporting](https://ksandk.com/energy/foreign-investors-indian-infrastructure/) (“BRSR”) framework has also increased the importance of standardised ESG disclosures by listed entities. The BRSR framework requires specified listed entities to make structured disclosures relating to their environmental, social and governance performance. SEBI has additionally introduced the BRSR Core framework, which provides for a set of key ESG indicators and a phased framework for reasonable assurance.  As ESG disclosures become increasingly standardised and subject to assurance requirements, companies should ensure that information disclosed in sustainability reports and other regulatory communications is supported by appropriate internal records, methodologies and evidence.  ## Enforcement Trends and Judicial Developments Environmental claims in India have historically been addressed to a significant extent through advertising self-regulation and general consumer protection mechanisms. ASCI has acted against advertisements containing unsupported or misleading environmental claims. Examples have included claims that products were “100% natural” or “chemical-free”, unsupported biodegradability claims and other representations concerning environmental or [energy-related characteristics](https://ksandk.com/energy/aerial-right-of-way-transmission-line-compensation/). These cases illustrate the types of environmental representations that may attract scrutiny where they are not adequately substantiated.  The CCPA Guidelines provide a more specific framework for addressing misleading environmental claims and are therefore likely to become increasingly important in assessing the compliance of consumer-facing green claims.  At the same time, there remains limited reported Indian judicial precedent specifically interpreting the CCPA’s 2024 Greenwashing Guidelines. This leaves several questions that may require greater regulatory or judicial clarification, including the level and nature of substantiation required for different categories of environmental claims, the circumstances in which a general corporate sustainability statement becomes a product or service-specific claim, and the manner in which different forms of scientific evidence or third-party verification should be assessed.  The regulatory landscape is therefore still developing. Businesses should not, however, treat the limited judicial precedent as an absence of legal risk. Existing consumer protection, advertising and securities regulations can apply independently depending on the nature of the representation.  ## Key Compliance Considerations for Businesses Businesses making environmental or ESG-related claims should consider implementing a structured review process before publishing such claims.  **Substantiate environmental claims**: Companies should maintain reliable evidence supporting the environmental representations they make. Claims such as “100% recyclable”, “carbon neutral”, “zero emissions”, “biodegradable” or “100% natural” should not be made without an appropriate factual and evidentiary basis.  **Avoid vague and absolute claims**:Broad terms such as “green”, “clean”, “sustainable” and “eco-friendly” can create a misleading impression if they are not adequately qualified or explained. Businesses should clearly identify the specific environmental attribute being claimed.  **Maintain supporting records**:Companies should retain the studies, data, certifications, methodologies and other material relied upon to substantiate environmental claims. This can be particularly important if a claim is subsequently challenged by a regulator, consumer or competitor. **Review future-oriented claims carefully**:Claims relating to future environmental objectives, including net-zero or carbon-neutral targets, should be supported by a credible implementation strategy and should not create an impression that a target has already been achieved when it remains aspirational.  **Ensure consistency across disclosures**:Environmental claims appearing in advertisements, websites, sustainability reports, investor presentations, BRSR disclosures and other corporate communications should be consistent. A company should avoid making an environmental claim in marketing material that cannot be reconciled with its regulatory or sustainability disclosures.  ## Conclusion Greenwashing is emerging as an increasingly significant legal and compliance issue for businesses operating in India. As environmental considerations become more important to consumers, investors and regulators, businesses have a greater commercial incentive to communicate their environmental credentials. At the same time, misleading or inadequately substantiated claims can expose businesses to regulatory, reputational and potentially financial consequences.  India’s regulatory framework is developing across multiple dimensions. The CCPA Guidelines provide a specific framework for preventing and regulating misleading environmental claims, while ASCI’s guidelines establish standards for environmental claims in advertising. SEBI’s framework addresses greenwashing risks in the securities market, including green and other ESG-related debt securities, while the BRSR and BRSR Core frameworks continue to increase the importance of accurate and supportable [ESG disclosures](https://ksandk.com/energy/foreign-investors-indian-infrastructure/).  The absence of extensive judicial precedent on the CCPA’s 2024 Greenwashing Guidelines means that certain interpretive questions remain open. However, businesses should not wait for litigation or regulatory action before addressing these risks.  Companies making environmental or ESG-related claims should therefore adopt appropriate internal review and substantiation mechanisms, maintain supporting evidence, obtain independent verification where appropriate, and ensure that environmental claims are accurate, transparent and consistent across their marketing and regulatory disclosures. For businesses, the central compliance principle is straightforward: environmental claims should be capable of being demonstrated, not merely advertised.  ## **Frequently Asked Questions** ### 1. What is greenwashing under Indian law? Greenwashing refers to misleading, exaggerated or unsubstantiated claims about the environmental benefits of a product, service or business. The CCPA Guidelines, 2024 define it broadly to cover concealment, omission and misrepresentation of environmental information. ### 2. Which regulators govern greenwashing in India? India does not have a single anti-greenwashing law. Instead, the CCPA, ASCI and SEBI each regulate different aspects, covering consumer protection, advertising standards and securities disclosures respectively. ### 3. What are the CCPA Guidelines on greenwashing? The CCPA Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024 require businesses to ensure their environmental claims are truthful, substantiated and not misleading to consumers. ### 4. How does SEBI address greenwashing risks? SEBI regulates greenwashing through its framework for green debt securities and ESG disclosures, requiring proper use of proceeds, accurate reporting and honest representation of environmental credentials to investors. *Last Updated on 12 August, 2026* Get King Stubb & Kasiva’s legal updates in your Google feed[![Add King Stubb & Kasiva as a preferred source on Google](https://ksandk.com/wp-content/uploads/google_preferred_source_badge_light_en@2x.png)](https://www.google.com/preferences/source?q=https://ksandk.com/) --- ## Office Locations - [New Delhi](https://ksandk.com/locations/top-corporate-law-firm-in-delhi/) (HQ): +91-11-41318190 | info@ksandk.com - [Mumbai](https://ksandk.com/locations/top-corporate-law-firm-in-mumbai/): 3 offices (Nariman Point, Lower Parel, Andheri) | mumbai@ksandk.com - [Bangalore](https://ksandk.com/locations/top-corporate-law-firm-in-bangalore/): bangalore@ksandk.com - [Chennai](https://ksandk.com/locations/chennai/): chennai@ksandk.com - [Hyderabad](https://ksandk.com/locations/hyderabad/): hyderabad@ksandk.com - [Pune](https://ksandk.com/locations/pune/): pune@ksandk.com - [Kochi](https://ksandk.com/locations/kochi/): kochi@ksandk.com ## Contact - [Contact Page](https://ksandk.com/contact-us/) - General: info@ksandk.com | +91-11-41318190 - WhatsApp: +91-7428567444 - [Privacy Statement](https://ksandk.com/privacy-statement/) - [Terms of Use](https://ksandk.com/terms-of-use/)