ClientEarth Communications
26th March 2025
In our first greenwashing complaint against a financial institution, we filed a complaint against the investment company BlackRock, for misleading marketing.
In the complaint, we stated that BlackRock was greenwashing, as investment funds the company was calling 'sustainable' really weren’t, as they have poured over a billion into fossil fuel companies including Shell and BP.
Since we filed our complaint, in March 2025 BlackRock announced changes to many of its funds previously labelled as 'sustainable' and 'ESG'. This included 17 of the 18 that our complaint covered. BlackRock explained that these changes were to comply with ESMA’s new fund naming guidelines. But we maintain that regulators should act where investors have been misled.
With a portfolio of US $9 trillion, BlackRock is the world’s largest asset management company. Private individuals, pension funds, banks and others entrust BlackRock to manage their savings and in turn BlackRock invests this money on their behalf in companies around the world.
A significant amount of those investments go into fossil fuel companies, the vast majority of which are developing new projects or capacity. To date, BlackRock is the second largest institutional investor in fossil fuels overall with $400 billion worth of investments in the industry.
BlackRock manages hundreds of investment funds in its portfolio, and a segment of these are marketed as “sustainable”. However, many of these so-called “sustainable” funds have invested over a billion in fossil fuel companies, the vast majority of which are developing new projects or capacity. This includes the likes of TotalEnergies, Shell, BP, Chevron, Conoco Phillips and Equinor.
We believe that this means BlackRock is greenwashing by calling these funds “sustainable”, and investors and the public need to know.
We know that investors in France and elsewhere want to take sustainability into account in their investment choices – including fossil fuel expanders in ‘sustainable funds’ stops them doing that and undermines the integrity of the market for sustainable financial products.
Greenwashing is where a company uses labelling, marketing and public messaging to try to appear to be environmentally sustainable and green – greener than it really is. It’s also a technique used by certain companies to distract consumers from the fact that their business model and activities actually do a lot of environmental harm.
In October 2024, we filed a letter of complaint to the French financial regulator - the Autorité des marchés financiers (AMF), to flag BlackRock’s greenwashing practices.
Building on analysis from French organisation Reclaim Finance, we identified 18 actively managed retail investment funds marketed in France with ‘sustainable’ in their names, which collectively hold more than US$1 billion of fossil fuel investment, the majority of which represents fossil fuel expansion. This is why we filed the complaint to the French regulators.
This action was to test what is actually meant by 'sustainable' in investment fund marketing for the first time. If we were to have had an encouraging result, it could have set a new standard for investment funds when it comes to both fossil fuel financing and sustainable finance.
Our analysis shows that through BlackRock’s so-called ‘sustainable’ funds, investors are unwittingly being exposed to investments worth billions in fossil fuel companies. Exaggerated sustainability claims create a competitive advantage for these BlackRock funds, distorting competition in the market and diverting capital flows away from genuinely sustainable products.
In response to the filing of the complaint, a BlackRock spokesperson said:
“BlackRock funds are managed in accordance with their investment objectives, which are clearly stated in each fund's prospectus and on the website.”
They also said they comply with all regulations on sustainable investment.
Since the complaint was filed, BlackRock announced changes to many of its funds previously labelled as ‘sustainable’ or ‘ESG’. This includes 17 of the 18 ‘sustainable’ funds that we covered in our complaint.
BlackRock explained that these changes are to comply with ESMA’s new fund naming guidelines. But we maintain that regulators should act where investors have been misled.
We wanted to see three main things as a result of this complaint:
This would give the public clarity on what the word “sustainable” means when it comes to investments and help stop the misallocation of investment to some of the least sustainable companies in the world – which could have impact far beyond this complaint.
Now the complaint has been filed, it’s up to the regulator (AMF) to take it forward or not. We’ll be keeping up public pressure on BlackRock and we will also be notifying the European financial regulator (ESMA) of the action we’re taking.