Greenhushing is a paradoxical phenomenon where some actors prefer to stop communicating about their sustainability commitments to avoid greenwashing accusations. This phenomenon is driven by regulatory tightening and litigation risk, which harms the overall transparency of the market.

The French Asset Management Association (AFG) and the Forum for Responsible Investment (FIR) proposed a national definition of SRI in 2013, stating that SRI is an investment that aims to reconcile economic performance with social and environmental impact. This definition is important because it was adopted at the national level and remains broad enough to encompass diverse practices.

More than twenty jurisdictions representing nearly 55% of global GDP have decided to use or are taking steps to introduce IFRS S1 and S2 standards. These standards were published in June 2023 by the ISSB to harmonize sustainability disclosures at the international level.

The transatlantic divergences between the EU, which continues its regulatory ambition with frameworks such as the SFDR and the Taxonomy, and the United States, which adopted a deregulation trajectory since 2024-2025, were not resolved by an international agreement in 2025. This divergence creates challenges for international asset managers.

The Global Sustainable Investment Alliance (GSIA) defines sustainable investment as an approach that considers ESG (environmental, social, and governance) factors in portfolio selection and management. Although social criteria are part of ESG factors, the definition does not specify that they must be mandatorily included, which may vary depending on the approach.

The EU Taxonomy (Regulation EU 2020/852) establishes that to be considered environmentally sustainable, an activity must contribute substantially to one of the six defined environmental objectives, without causing significant harm to the others. These objectives are specific and structured, which contrasts with more flexible approaches adopted elsewhere.