Greenwash Risk — Detecting Disclosure Drift in 2026
Cross-checking voluntary registries against SEC, EFRAG and ISSB filings to surface gaps between claimed and verified credits.
Abstract
Disclosure drift — the gap between a company's marketing claims and the credits it has actually retired on-chain or on-registry — has widened in 2026. This note documents the methodology, the twelve constituents now flagged High, and the implications for index weighting at the next rebalance.
Key Findings
- 01Aggregate C100 claimed retirements (FY2025 reports) overstated registry-verified retirements by 14.2%.
- 02The gap is concentrated in eight sectors: airlines, oil & gas, fast fashion, e-commerce, cement, shipping, steel, and consumer tech.
- 03Twelve constituents move from Medium to High greenwash risk; three move from Low to Medium.
- 04Firms that publish serialized retirement IDs in their sustainability report show a 92% match rate; those that don't show 61%.
1. What 'disclosure drift' actually means
We define disclosure drift as the percentage difference between (a) the volume of carbon credits a company claims in its annual sustainability report and (b) the volume that can be tied to a serialized retirement on a recognized registry within ±90 days of the reporting period.
Drift is not necessarily fraud — it can reflect pipeline credits, future-vintage commitments, or accounting timing. But persistent positive drift correlates with later restatements and regulator scrutiny.
2. Sector breakdown
Airlines and fast fashion show the widest gaps, both above 25%. Cement and steel — historically the most criticized — actually show the narrowest drift (~6%), reflecting tighter compliance-market overlap.
3. The twelve High-risk upgrades
The full list is published in Appendix A of the underlying dataset. We will not name individual constituents in this commentary ahead of the Q2 rebalance consultation window, which closes 2026-06-15.
Disclosure drift by sector (FY2025)
| Sector | Claimed (Mt) | Verified (Mt) | Drift |
|---|---|---|---|
| Airlines | 18.4 | 13.7 | +34.3% |
| Fast Fashion | 9.1 | 7.2 | +26.4% |
| E-commerce | 22.6 | 18.9 | +19.6% |
| Consumer Tech | 31.2 | 27.0 | +15.6% |
| Oil & Gas | 44.8 | 39.1 | +14.6% |
| Shipping | 12.0 | 10.8 | +11.1% |
| Cement | 27.5 | 26.0 | +5.8% |
| Steel | 19.3 | 18.4 | +4.9% |
Implications
- →Expect Q2 2026 rebalance to reduce aggregate index weight on the twelve High-risk names by ~110 bps.
- →Allocators with claim-based exclusion policies should re-run their screens against registry-verified figures, not reported figures.
- →Companies disclosing serialized retirement IDs in real time should see a tailwind from improved match rates.
Methodology
- • Claimed figures: extracted from FY2025 sustainability reports filed Jan-Apr 2026.
- • Verified figures: union of Verra, Gold Standard, ACR, ART, CAR, Puro, Isometric retirement records.
- • Matching: serialized IDs first; fallback to project+vintage+vintage-year fuzzy match with 90-day window.
- • Threshold: drift >15% triggers Medium → High; drift 5-15% triggers Low → Medium.
Sources & References
This research note is published by the Carbon Index Protocol research desk for informational purposes only. It does not constitute investment advice, an offer to sell, or a solicitation to buy any security or carbon instrument. C100 scores and weights are derived from public filings, registry data, and proprietary models; figures may be revised as new information becomes available.