Picture a Monday morning in the sustainability function of a mid-sized European manufacturer. The Head of Sustainability — let us call her Sophie — sits before two screens. On the left, a draft of the company’s annual climate report, substantially complete but containing a candid admission: Scope 3 emissions, those generated across the full value chain by suppliers and customers, were not measured this year. The data was too difficult to collect; the suppliers too small and too numerous to engage meaningfully. On the right screen, a news alert: a prominent environmental NGO has just named three companies in Sophie’s sector as greenwashers. Their offence? Publishing climate targets that excluded Scope 3. Sophie’s dilemma is modern, practical and very nearly Shakespearean. To report — openly, with every gap and limitation laid bare — or not to report, and join the quiet ranks of companies that have concluded, rationally if not always admirably, that silence is safer than scrutiny.
This is the tightrope. On one side lies the risk of greenwashing — making claims, implicitly or explicitly, that exceed the substance of a company’s actual environmental performance. On the other lies its increasingly prevalent cousin, greenhushing — the deliberate suppression of climate disclosures, not because a company has nothing to say, but because saying it, in a political and regulatory environment grown suddenly turbulent, feels too dangerous. Between these two precipices, a generation of sustainability professionals is attempting to walk a line with no safety net below.
The 96 Per Cent Problem
The scale of the challenge became starkly quantifiable in February 2026, when Elizabeth Brown, Angel Hsu, and Diego Manya published what is arguably the most comprehensive empirical audit of corporate climate commitments yet attempted. Analysing over 4,000 companies against seven distinct dimensions of climate reporting integrity — drawing on CDP disclosure data, InfluenceMap’s LobbyMap and the Net Zero Tracker — they found that 96% of pledging companies exhibit at least one red flag. For those making the more ambitious claim of net-zero alignment, the figure barely shifts: 95.8%.
What is striking is not just the headline figure, but its architecture. The seven failure modes are only weakly correlated with one another: a company that falls short on carbon offsets is not reliably more likely to be misaligned on lobbying, and one that lacks interim targets may have a credible implementation plan. The failures are dispersed rather than concentrated. Which means — and this is the uncomfortable implication — that a company could be trying in good faith on six dimensions while inadvertently, or perhaps deliberately, falling short on the seventh. Greenwashing, the research suggests, is less often the product of cynical invention than of structural incompleteness.
CDP’s own data tells a parallel story. In 2024, a record 22,700 companies disclosed through its platform — disclosure volumes are rising, not falling. Yet only 2% achieved a top A rating. The crisis, as one recent analysis put it, is not in the quantity of what is being disclosed — it is in the honesty and completeness of what sits behind the numbers.
Seven Dimensions, One Checklist
The Brown, Hsu and Manya framework — grounded in the UN High-Level Expert Group’s integrity standards and ISO net-zero guidelines — is worth pausing on, because it offers the most practically useful checklist available for anyone in Sophie’s position. These are not arcane academic constructs. They are the specific dimensions on which, at this very present moment, companies are being found wanting.
The most prevalent failure — present in 70% of all pledging companies — is Scope 3 exclusion. Companies set targets covering only their direct and energy-related emissions, omitting the indirect emissions across their supply chains and customer base. For many industries, especially Financial Services, Scope 3 constitutes the overwhelming majority of actual impact, so a target that omits it can appear far more ambitious than it is. Next comes the use of questionable carbon offsets, present in 40% of companies overall and rising to 69% among explicit net-zero pledgers — with a separate body of research suggesting that 87% of the offsets used to support net-zero claims carry high risk of failing to deliver genuine reductions. Missing interim targets affect 21% of companies: a 2050 commitment with no 2030 milestone creates no accountability in the near term and permits indefinite deferral without technically breaking the pledge. The absence of an implementation plan — how the company will actually get from here to there — is a failing in 18% of all pledging companies, and notably worse among those making the most ambitious claims. Lack of demonstrated progress, the dimension that most directly captures the say-do gap, is present in 20%. A company can hold its net-zero target on paper while its emissions continue to rise; without annual performance data, that divergence is invisible to the outside world. GHG coverage discrepancy — claiming carbon neutrality while the underlying targets do not comprehensively cover all emission scopes — affects 11% of companies and represents a more active form of misrepresentation. And finally, misaligned lobbying: 10% of companies overall, but 57% in fossil fuels and 70% in metals and mining, publicly commit to climate targets while simultaneously lobbying against the government policies needed to achieve Paris Agreement goals.
This last dimension deserves particular emphasis because it is entirely invisible in corporate sustainability reports. A company can publish a detailed, beautifully formatted climate disclosure — one that scores reasonably well on the first six dimensions — while its trade association lobbies in Brussels or Washington against the very carbon pricing mechanisms that would make the whole commitment credible. The gap between what companies say in public and what they advocate behind closed doors is arguably the most structurally dishonest form of greenwashing precisely because it cannot be detected by reading the report.
The Silence That Speaks
If greenwashing is the disease of saying too much, greenhushing is its quieter pathology — saying too little, or nothing at all. ESG mentions on S&P 500 earnings calls peaked in late 2021 and have been declining steadily since. Major financial institutions — HSBC and a string of large US banks among them — withdrew from the Net-Zero Banking Alliance in late 2024 and early 2025. In Canada, anti-greenwashing legislation has paradoxically accelerated silence: many companies have removed or sanitised disclosures rather than risk litigation.
The academic literature offers a clarifying distinction that is easy to miss in the noise. Researchers who study greenhushing carefully separate two phenomena: companies that are genuinely taking climate action but staying quiet about it, and companies that have simply stopped making claims they cannot substantiate. For the latter, what looks like greenhushing is, more charitably, the cessation of greenwashing. The silence, in these cases, may be appropriate. But it is not costless: it deprives markets, investors and regulators of information they need to allocate capital efficiently, and it deprives supply chain partners — smaller companies trying to measure their own Scope 3 footprint — of the upstream data they require.
A separate and more troubling pattern has emerged in 2025 under the term ‘greenrinsing’: the practice of setting ambitious targets to attract investors and ESG-minded customers, only to quietly water them down or drop them once the capital has been raised. Air New Zealand, Shell, BP, Unilever, Volvo, and Coca-Cola have all been cited in connection with weakened or delayed sustainability commitments. This is neither honesty nor silence — it is a third path, and arguably the most corrosive of the three.
Sympathy for the Tightrope Walker
It would be convenient, and wrong, to frame this as a story about corporate bad faith. Sophie’s dilemma, and that of thousands of sustainability professionals in similar positions, is real and it deserves a measure of sympathy. The regulatory environment has rarely been more contradictory. In the EU, mandatory disclosure standards under the CSRD are tightening and raising the quality bar. In the US, the SEC voted in March 2025 to abandon its legal defence of the Climate Disclosure Rule, calling it ‘costly and unnecessarily intrusive’ — creating a vacuum where guidance had once existed. The UK’s Competition and Markets Authority has moved from publishing its Green Claims Code to enforcing it, with large-scale action beginning in autumn 2025. A company operating across these jurisdictions faces simultaneously contradictory signals: disclose more; be prepared to defend every word; accept that anything you say may be used against you.
The data-gathering challenges are real too. Measuring Scope 3 emissions for a company with a complex global supply chain is genuinely difficult. Engaging hundreds of small, resource-constrained suppliers on emissions data is not something that can be mandated unilaterally or funded from a modest sustainability budget. Missing that dimension does not necessarily signal bad intent — it may signal limited capacity, imperfect methodology or the simple fact that the logic of supply-chain emissions accounting is still evolving. ShareAction’s review of asset manager disclosures found that ‘credible, clear disclosures are possible — but they are still far from the norm,’ a finding that reflects institutional constraints as much as institutional will.
Behavioural economics — a discipline that has increasingly informed thinking about why the gap between stated environmental commitment and actual corporate behaviour is so persistent — offers a structural explanation here that is as relevant to corporate reporting teams as it is to individual consumers. Loss aversion kicks in and a certain reputational risk of disclosing a gap feels more acute than the uncertain future benefit of demonstrating honesty. Present bias also holds back corporates – the immediate risk of a critical NGO report outweighs the long-term reward of building a reputation for trustworthy disclosure. Status quo bias also plays it part; the default position — generating a report that looks broadly similar to last year’s — is psychologically easier than a more ambitious exercise that opens new questions. These are not excuses. They are the human and organisational dynamics that any serious attempt to improve disclosure quality has to design around.
Where Sympathy Ends
Empathy, however, has limits. The seven dimensions identified by Brown, Hsu and Manya are not an arbitrary academic checklist. They are derived from the UN HLEG’s ‘Integrity Matters’ framework — a set of standards developed precisely because the gap between climate rhetoric and climate action has material consequences: for the climate, for investors allocating capital on the basis of disclosed commitments, and for smaller companies whose own Scope 3 obligations depend on the accuracy of what their larger supply chain partners say they are doing.
Failing to demonstrate progress against targets is not a data problem — it is a disclosure choice. Publishing a net-zero target with no interim milestones is not a resource constraint — it is a structural decision that insulates the commitment from accountability. And lobbying against the government policies required to achieve Paris Agreement goals, while simultaneously publishing climate pledges, is not an oversight — it is a contradiction that goes to the heart of whether the commitment is real. Sophie may deserve our understanding when she struggles to measure Scope 3 across a fragmented supplier base. She does not deserve it if the company’s trade association is, at the same time, arguing in Westminster that carbon pricing is economically unacceptable.
The distinction that matters most is between accidental and intentional shortfall. Accidental greenwashing — incomplete disclosure driven by data gaps, resource constraints or evolving methodology — is a problem that can, with effort and good faith, be resolved. Intentional greenwashing — the deliberate exclusion of inconvenient data, the deployment of offsets to avoid real reductions, the maintenance of a public climate identity incompatible with private political advocacy — is a different matter entirely. It is the difference between a tightrope walker who slips and one who never intended to cross.
A Better Way Across
The Brown, Hsu and Manya framework, taken seriously, is not a counsel of despair. Its seven dimensions function as a roadmap as much as a report card. A company that uses it honestly as a self-assessment tool — asking which of the seven it currently fails on, and why — is already doing something that 96% of pledging companies are not. The answer to greenwashing risk is not silence. Greenhushing does not reduce reputational exposure in any environment where regulators are gaining enforcement powers; it reduces only the chance that external scrutiny surfaces problems before internal ones do.
What is needed is neither more volume nor more silence — it is better architecture. Interim milestones that create short-term accountability. Implementation plans that explain the mechanism, not just the destination. Honest guidance on the use of offsets that distinguishes between those that represent genuine, additional and permanent reductions and those that are, at best, a temporary fix. Scope 3 measurement that is transparent about its methodology and limitations, rather than simply absent. And a lobbying posture that is consistent with, rather than corrosive of, the public commitments made.
Back at her desk, Sophie has a third option she may not yet have considered. She could publish the report with the Scope 3 gap clearly disclosed, with an explanation of why it exists and a credible plan for addressing it. She could note, in plain language, that the company has not yet demonstrated progress on reducing Scope 1 and 2 emissions, and explain what it intends to do differently. She could describe the implementation plan as a work in progress, because it is. None of this is comfortable. But it is honest. And in an environment where both greenwashing and greenhushing carry growing legal, reputational and market consequences, honesty — delivered with appropriate rigour across the seven dimensions that may going forward constitute the accepted standard of credibility — may turn out to be the only stable ground on the rope.
The tightrope is real, and the drop on either side is real. But the wire itself is not the problem. The question is whether the walker is moving forward.
