Walk down the aisle of any Indian supermarket today, and you will be surrounded by a chorus of virtue: "eco-friendly", “100% natural", "plastic-positive", and "carbon-neutral". Open the annual report of a large listed company, and the chorus swells into a symphony—net-zero pledges, circular-economy roadmaps, and glossy photographs of saplings. 'Sustainability' has become the most valuable vocabulary in Indian business. The uncomfortable question is: how much of this language is backed by action, and how much of it is greenwashing—communication engineered to appear green rather than to be green?
Greenwashing Is a Communication Problem Before It Is an Environmental One
Greenwashing is often imagined as outright lying. In practice, it rarely is. The classic academic literature describes it as the intersection of poor environmental performance and positive environmental communication (Delmas & Burbano, 2011)—a gap sustained not by falsehoods but by selective disclosure, vague terminology, decoupled promises, and strategically ambiguous language (Lyon & Montgomery, 2015). A firm can technically state facts and still leave the reader with a misleading impression: highlighting a recycled package while staying silent on emissions, celebrating a pilot project while the core business remains carbon-intensive, or wrapping weak commitments in confident, upbeat prose.
This is why sustainability communication—not just sustainability performance—deserves scholarly and regulatory attention. The deception lives in the language: in tone, in what is omitted, in the ratio of aspiration to evidence. My own research stream on corporate disclosure analysis examines precisely this layer, using natural language processing and explainable AI to detect linguistic markers of deceptive tone in sustainability and supply chain disclosures. When machine learning models are combined with interpretability tools such as SHAP, we can move beyond a binary “green or not green” verdict and identify which textual features—hedging, self-praise, low specificity, and an excess of forward-looking claims—drive a disclosure toward deception. Explainability matters here for the same reason it matters everywhere in analytics: a greenwashing “score” that cannot be interrogated is itself a black box asking to be trusted on faith.
The Indian Context: A Regulatory Turn in 2024
For years, India had no dedicated instrument against greenwashing; misleading green claims were policed, if at all, under general advertising and consumer protection law. That changed decisively in 2024. In February, the Advertising Standards Council of India (ASCI) brought into force its Guidelines for Advertisements Making Environmental/Green Claims, requiring that absolute claims such as “eco-friendly” or “sustainable” be substantiated by robust data and credible accreditation and that claims be limited to the specific part of the product that actually delivers the benefit (ASCI, 2024). The concern was not hypothetical: ASCI had earlier processed complaints against 116 advertisements in a single year for potentially misleading green claims.
In October 2024, the Central Consumer Protection Authority (CCPA) issued the Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024. The guidelines define greenwashing broadly—covering concealment, omission, exaggeration, vague or unsubstantiated claims, and misleading imagery—and require that terms such as "compostable", "recyclable", "net-zero", or “climate-positive” be supported by credible certification or verifiable scientific evidence (CCPA, 2024). Crucially, aspirational and futuristic claims are permitted only when backed by clear, actionable plans. Enforcement flows through the Consumer Protection Act, 2019, under which penalties for misleading advertisements can reach ₹10 lakh for a first offence and ₹50 lakh for repeat contraventions, alongside endorsement bans.
On the capital markets side, SEBI has been building the disclosure infrastructure that makes greenwashing detectable in the first place. The Business Responsibility and Sustainability Report (BRSR) applies to the top 1,000 listed companies, and the BRSR Core framework subjects a set of key ESG indicators—greenhouse gas emissions, energy, water, waste, gender diversity, and more—to mandatory reasonable assurance on a phased “glide path” that began with the top 150 firms in FY 2023–24 and extends to the full top 1,000 by FY 2026–27 (SEBI, 2023b). Third-party assurance directly targets the credibility gap at the heart of greenwashing: it converts narrative into auditable numbers.
From Claims to Consequences: Proven Incidents
Greenwashing is no longer a theoretical risk—regulators and courts have now proven it, punished it, and priced it. The most instructive case for India remains Volkswagen’s “Dieselgate”: beyond global penalties exceeding US$34 billion, the National Green Tribunal fined the carmaker ₹500 crore in 2019 for deploying emission “cheat devices” in diesel cars sold in India, ordering the amount deposited with the Central Pollution Control Board (NGT, 2019, as reported in Business Standard). In financial markets, Deutsche Bank’s asset management arm DWS—which had marketed ESG as “part of its DNA”—paid a US$19 million SEC penalty in 2023 for misleading statements about its ESG integration processes, followed by a €25 million fine from Frankfurt prosecutors in 2025, the largest greenwashing penalty ever imposed in Germany (SEC, 2023; ESG Dive, 2025). The SEC has since fined Goldman Sachs (US$4 million, 2022) and Invesco (US$17.5 million, 2024) for overstated ESG claims and Keurig US$1.5 million in 2024 for inaccurate recyclability statements in its annual reports. The pattern across these cases is telling: in almost none of them were the underlying numbers fabricated. What was punished was the communication—language that promised more than the organisation practised. Figure 1 summarises the monetary penalties across these proven incidents, underscoring that regulators worldwide, including in India, are now attaching real financial consequences to deceptive sustainability talk.
Figure 1. Monetary penalties in proven greenwashing enforcement actions, 2019–2025 (author’s compilation from regulatory and media sources; Indian case highlighted).
Greenwashing on Indian Shelves: Evidence from ASCI Rulings
Closer home, India’s advertising self-regulator has already built a small but telling case record. The ASCI’s Consumer Complaints Council upheld a complaint against The Body Shop’s claim that a product tube was “made with 30% recycled plastic", finding the assertion unsupported by independent third-party data, and pulled up Brown Living Studio for exaggerated “eco-friendly” claims on its peppermint toothpaste made without robust evidence or credible accreditation (S.S. Rana & Co., 2025). Published ASCI complaint outcomes against smaller brands—an “eco-friendly” natural hand wash and a “natural” fruit-and-vegetable cleaner—similarly held the claims misleading and “likely to lead to widespread disappointment” among consumers (Cyril Amarchand Mangaldas, 2024). Other prominent complaints—allegations that a leading “100% natural” soap contained synthetic ingredients or that an air-conditioner maker overstated energy efficiency—remain unproven signals of scrutiny rather than adjudicated deception. The aggregate picture, however, is difficult to dismiss: an ASCI study found that 79% of green claims made by organisations were exaggerated or misleading, while YouGov survey data indicate that 71% of Indian consumers have encountered greenwashing and only 29% trust corporate environmental claims (Outlook Business, 2024). Two features distinguish the Indian record. First, unlike the monetary penalties in Figure 1, Indian outcomes have so far been dominated by orders to withdraw or modify advertisements; the CCPA’s 2024 guidelines are simply too young to have generated landmark penalty orders. Second, the scrutiny is spreading from shelves to securities: SEBI’s circular on green debt securities expressly defines greenwashing as making “false, misleading, unsubstantiated, or otherwise incomplete claims” about sustainability (SEBI, 2023a)—confirmation that in India, too, the battleground is shifting to the language of disclosure itself.
Why Language Still Escapes the Auditors
Yet assurance covers numbers, not narratives. The qualitative sections of a BRSR filing, the sustainability chapters of annual reports, and advertising copy remain largely unaudited territory—and this is exactly where deceptive tone thrives. International evidence has long suggested that the overwhelming majority of green product claims commit at least one “sin” of greenwashing, most commonly the sin of the hidden trade-off or vagueness (TerraChoice, 2010)—and the ASCI’s own finding that 79% of green claims are exaggerated or misleading confirms that Indian corporate communication is no exception. As BRSR pushes quantitative honesty, the temptation may simply migrate into the prose: firms disclosing accurate numbers while dressing them in language that inflates achievement and buries risk.
This is where computational disclosure analysis can complement regulation. NLP-based screening tools can flag disclosures whose linguistic profile—low specificity, high optimism, heavy hedging—diverges from their underlying performance data, giving regulators, assurance providers, and investors a triage mechanism. Recent work in this direction, including research on deceptive tone in sustainable supply chain disclosures (Muhammed Niyas et al., 2026), suggests that deception is measurable, explainable, and—importantly—distinguishable from mere enthusiasm. In a market where the top 1,000 firms now generate thousands of pages of sustainability text annually, human reading alone cannot police that gap.
The Way Forward
Three implications follow. For managers, the era of costless green rhetoric is ending: with CCPA penalties, ASCI scrutiny, and SEBI assurance converging, sustainability communication must now be treated with the same discipline as financial reporting—specific, evidenced, and conservative. For business schools, sustainability communication belongs in the analytics classroom as much as in the marketing one; students should learn to interrogate a net-zero claim the way they interrogate a balance sheet. And for researchers, India offers a natural laboratory: a young, rapidly hardening regulatory regime, a mandated disclosure corpus, and a genuine societal stake in ensuring that the green transition is real. The words companies choose are data. It is time we read them that way.
References
Advertising Standards Council of India. (2024). Guidelines for advertisements making environmental/green claims. ASCI. https://www.ascionline.in/
Business Standard. (2019, March 7). NGT fines Volkswagen Rs 500 crore for ‘cheat device’ in India diesel cars. https://www.business-standard.com/
Central Consumer Protection Authority. (2024). Guidelines for prevention and regulation of greenwashing or misleading environmental claims, 2024. Department of Consumer Affairs, Government of India. https://consumeraffairs.nic.in/
Cyril Amarchand Mangaldas. (2024, October 3). Greenwashing – Drawing a line between green marketing or green misrepresentations. India Corporate Law Blog. https://corporate.cyrilamarchandblogs.com/
Delmas, M. A., & Burbano, V. C. (2011). The drivers of greenwashing. California Management Review, 54(1), 64–87. https://doi.org/10.1525/cmr.2011.54.1.64
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Lyon, T. P., & Montgomery, A. W. (2015). The means and end of greenwash. Organization & Environment, 28(2), 223–249. https://doi.org/10.1177/1086026615575332
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Outlook Business. (2024, May 30). ASCI moves to curb greenwashing with new guidelines. https://www.outlookbusiness.com/
S.S. Rana & Co. (2025, July 15). Greenwashing – Marketing gimmick or deceptive trade practice? https://ssrana.in/
Securities and Exchange Board of India. (2023a, February 3). Dos and don’ts relating to green debt securities to avoid occurrences of greenwashing (Circular). SEBI. https://www.sebi.gov.in/
Securities and Exchange Board of India. (2023b). BRSR Core – Framework for assurance and ESG disclosures for value chain (Circular No. SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122). SEBI. https://www.sebi.gov.in/
TerraChoice. (2010). The sins of greenwashing: Home and family edition. Underwriters Laboratories.
U.S. Securities and Exchange Commission. (2023, September 25). Deutsche Bank subsidiary DWS to pay $25 million for misstatements regarding ESG investments [Press release]. https://www.sec.gov/
U.S. Securities and Exchange Commission. (2024, September 3). SEC charges Keurig with making inaccurate claims regarding recyclability of K-Cup pods [Press release]. https://www.sec.gov/
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