The era of non-binding sustainability claims is coming to an end. By September 27, 2026, at the latest, your “green promise” must be backed by a strict, legally mandated obligation to provide evidence. The new EmpCo (Empowering Consumers) Directive marks the end of vague terms like “climate-neutral” or “ecological,” unless they can be substantiated by objective and scientifically sound data.

• New EU rules prohibit vague or unsubstantiated ESG claims
• Compliance requires traceable data and clear methodologies
• Independent validation is becoming essential for credibility

Assess your compliance readiness!

The EmpCo Directive marks a new level of market requirements for the financial sector. It applies to any economic operator that provides sustainability information to consumers in the EU. There is a particular need for action on the part of:

Your advantage: You, too, can benefit from a standardized process that is already being used successfully by industry leaders and fully supports EmpCo’s requirements.

The implementation of the (EU) 2024/825 Empowering Consumers (EmpCo) Directive marks a turning point in sustainability communication by replacing vague advertising claims with strict verification requirements. In the future, the use of generic environmental claims such as “environmentally friendly,” “ecological,” or “climate-neutral” will be prohibited unless companies can demonstrate recognized environmental performance relevant to the specific claim.

Regulations will be particularly strict regarding CO₂-related claims: Advertising claims that portray a product as “climate-neutral,” “reduced,” or “positive” solely through the offsetting of greenhouse gas emissions will be prohibited under all circumstances in the future. Such claims falsely suggest to consumers that consumption has no environmental impact or that the statement refers to the product itself, even though the offsetting takes place outside the value chain.

Promises regarding future environmental performance may also no longer be made without a substantial basis. Such statements are only permissible if they are supported by clear, objective, and publicly accessible commitments set forth in a detailed, realistic implementation plan with time-bound targets. This process must also be regularly monitored by an independent third-party auditor, whose findings must be made available to consumers.

In addition, transparency regarding sustainability labels will be significantly increased. In the future, labels may only be displayed if they have been established by government agencies or are based on an official certification system. Such a system must have been developed with the involvement of experts, be open to all stakeholders, and ensure objective monitoring by independent third parties. These new rules will take effect on September 27, 2026, following national implementation.

While the CSRD (Corporate Sustainability Reporting Directive) primarily requires companies to systematically and standardizedly collect and disclose sustainability data internally, the EmpCo Directive specifically addresses the external communication of this information to end customers. In doing so, the Directive establishes a binding link between reporting and market communication to ensure that environmental claims are well-founded and verifiable.

For financial and insurance products in particular, this represents a new level of regulation that comes with a special duty of care. In the future, sustainability assessments (ESG) may no longer be based on vague claims but must be grounded in a clear, scientifically sound methodology as well as objective and verifiable criteria.

A key aspect here is comprehensibility: to prevent consumers from making the wrong decisions, all information must be presented clearly, relevantly, and reliably so that consumers can understand a product’s actual sustainability at a glance. In this context, the burden of proof effectively shifts to the company: Advertisers must have the corresponding evidence—including the underlying data sources and methodologies—for every claim used fully documented and available for review.

To establish true comparability in the market for sustainable financial products, DIN 77236-2 defines uniform standards for their design and evaluation. Starting no later than September 27, 2026, this certified score will serve as decisive, objective evidence to legally substantiate sustainability claims in accordance with the new EmpCo guidelines.

For easy reference, the system works similarly to the well-known Nutri-Score for food: It makes complex sustainability claims visible at a glance, with the scale ranging from a dark green top rating (“A” for very sustainable) to a deep red range (“F” for unsustainable).

The rating is characterized by consistent, data-driven objectivity, as it is based on publicly available information from FinDaTex’s European ESG Template (EET). This ensures that marketing claims are no longer based on vague assertions but are grounded in the robust ESG data provided by asset managers. A key component of the methodology is also the detailed consistency check: Here, the consistency of the data is strictly monitored to ensure that the information in the product information sheet fully aligns with the investment strategy actually implemented.

To ensure that your portfolio is fully compliant in time for the launch on September 27, 2026, we will guide you through a highly efficient verification process. Our structured and standardized approach enables you to implement the EU’s complex regulatory requirements in a targeted manner. Our entire process complies with the strict EU requirements for certification systems, which mandate independent third-party audits as well as transparent and objective processes.

In the first step, we conduct a thorough product analysis in which the relevant sustainability characteristics of your financial product are recorded and evaluated based on the standardized FinDaTex-EET data sets. We then subject your product to a structured assessment in accordance with the uniform and traceable criteria of DIN 77236-2. We present all results in a transparent and verifiable manner, placing particular emphasis on the scientific basis of your claims to proactively rule out any greenwashing risks.

Upon successful completion of the assessment, you will receive official confirmation of compliance as well as your individual DIN sustainability score on a scale from A to F for your marketing communications.

The result is a robust foundation that makes your sustainability commitments transparent to both consumers and regulators at all times and positions your company in compliance with current EmpCo regulations.

The new EU Directive on Empowering Consumers for the Ecological Transition (EmpCo) presents insurers with a clear choice:

Either sustainability claims must be backed by objective and verifiable evidence, or they must be removed from marketing communications. Our certification under DIN 77236-2 is specifically designed to close this regulatory gap in a legally compliant manner.

Here are the three pillars that ensure our process fully meets EU requirements:

The era of non-binding sustainability claims will come to an end on September 27, 2026, when green advertising promises will be replaced by a strict obligation to provide evidence. Those who fail to take proactive action today risk not only accusations of greenwashing and legal sanctions in the future, but also the permanent loss of customer trust.

To effectively minimize the risk of greenwashing, vague terms such as “climate-neutral” or “ecological”—which will be prohibited in the future without scientifically sound evidence—must be replaced with reliable facts. The DIN Sustainability Score 77236-2 serves as recognized proof of EmpCo compliance—an objective rating system based on the Nutri-Score principle that provides transparency at a glance.

Follow the example of industry leaders such as Bayerische, Fidelidade, and Debeka, who have already recognized the strategic value of this verification through us and are successfully positioning their products in the market.