A Greenwashing Self-Audit Checklist: 18 Tests Before You Make a Climate Claim

Published 2026-05-06.

The EU's Empowering Consumers for the Green Transition Directive (applying from September 2026), India's CCPA Greenwashing Guidelines (2024), and FTC Green Guides (US) all sharpen enforcement; the separate EU Green Claims Directive proposal has stalled. The EU directive bans generic environmental claims and product claims of carbon neutrality based on offsetting, and penalties for widespread breaches of EU consumer law can reach at least 4% of turnover.

The 18 tests

Evidence

Do you have a documented baseline year and methodology?
Is your baseline verified by an independent third party?
Are emission factors sourced from a recognised database with citation?
Are calculations reproducible from raw bills and invoices?

Boundary

Have you stated which scopes are included (1, 2, 3)?
Have you disclosed Scope 3 categories included and excluded?
Have you included or explicitly excluded biogenic carbon?
Is the geographic and temporal boundary clear?

Claim language

Avoid "carbon neutral" without offset disclosure
Avoid "100% green" without renewable certification reference
Avoid "net zero" before 2030 unless validated by SBTi
Use specific numbers, not vague adjectives ("low-carbon")

Offsets

If using offsets, are they additional, permanent, verified?
Have you stated the % of footprint offset vs reduced?
Do offsets meet ICVCM Core Carbon Principles?

Improvement

Is there a year-on-year reduction trajectory disclosed?
Is the trajectory aligned with 1.5°C (4.2% absolute/year)?
Is there a transition plan with capex and timeline?

How regulators interpret each test

EU consumer law treats unsubstantiated environmental claims as misleading. The burden of proof is on the claimant.

Score yourself

16–18: Defensible. Publish.
12–15: Defensible with refinement. Publish a more modest claim.
8–11: Risky. Limit to internal use.
Under 8: Withdraw any external claim.

Building defence systematically

Senseible ledger captures evidence (1–4), full Scope (5–8), structured calculation (10–12). For (13–15) layer offset providers with ICVCM compliance only. For (16–18) use the Carbon Pricing Impact calculator to publish a forward trajectory.