Directive 2024/825 in Luxembourg: The 27 September Greenwashing Rules

Directive 2024/825 applies in Luxembourg from Sunday 27 September 2026. On 23 September the CSSF published a two-paragraph communication reminding market participants that Directive (EU) 2024/825, known as the ECGT Directive on empowering consumers for the green transition, has been transposed by the Law of 9 June 2026 amending the Consumer Code. The CSSF expects financial market participants to take due account of the new requirements, to make sure consumer-facing sustainability claims are “clear, accurate and duly substantiated”, and to make sure requirements imposed by law are not presented as a distinctive sustainability feature.

The stakes sit in the blacklist. From 27 September the Consumer Code treats five greenwashing practices as unfair in all circumstances: displaying a sustainability label that is neither based on a certification scheme nor set up by a public authority, making a generic environmental claim without recognised excellent environmental performance relevant to the claim, stretching a claim about one aspect to the whole product or business, claiming a neutral, reduced or positive greenhouse gas impact on the strength of offsetting, and presenting requirements imposed by law on all products in the relevant product category on the EU market as a distinctive feature of the trader’s offer. For those five there is no need to show that the practice changed an average consumer’s transactional decision. For a UCITS management company, an AIFM or an investment firm with retail clients, that reaches website copy, factsheets, adverts, app screens, label logos placed next to a product and, depending on context, the product name itself.

Nothing in the communication adds a return, a template or a notification to the CSSF reporting calendar, so the work lands in marketing review and in the evidence file behind each claim. The legal text sits in consumer law, which is also why the reading has to start with who counts as a consumer.

Related reading: CSSF SFDR FAQ Update: When Template Changes Need Sign-Off

Directive 2024/825 in Luxembourg: the dates that matter

• 28 February 2024: Directive (EU) 2024/825 adopted; published in the Official Journal on 6 March 2024 (OJ L, 2024/825).
• 26 March 2024: the Directive entered into force.
• 27 March 2026: deadline for Member States to adopt and publish their transposing measures (Article 4 of the Directive).
• 21 May 2026: the Chamber of Deputies adopts bill No 8648 at first constitutional vote and requests dispensation from a second vote; 9 June 2026: the Council of State grants that dispensation.
• 9 June 2026: Law of 9 June 2026 amending the Consumer Code, published in Memorial A No 283.
• September 2026: European Commission Questions and Answers on the ECGT Directive (reference dated 21 September 2026).
• 23 September 2026: CSSF communication on the entry into application of the new rules.
• 27 September 2026: the Luxembourg law enters into force under its Article 10, the date from which Article 4 of the Directive requires Member States to apply their measures.

Luxembourg adopted its law after the March 2026 transposition deadline, but the application date lines up with the Directive. Article 10 of the Luxembourg law says the law “entre en vigueur” on 27 September 2026, so nothing in it had legal effect between publication in June and that date. The Commission’s September 2026 Q&A adds that there is no transition period beyond 27 September 2026 for sustainability labels already in use.

The claim-related changes are concentrated in four places in the Code. Article L. 121-2 receives new definitions, with points 13 to 17 covering environmental claims, generic environmental claims, sustainability labels, certification schemes and recognised excellent environmental performance. Article L. 122-2 extends the misleading-actions test. Article L. 122-3 gains a new paragraph 8 on comparison services. Article L. 122-4, the blacklist, receives new points 28 to 39.

The remaining amendments, mainly to Articles L. 010-1, L. 113-1, L. 222-3, L. 222-4 and L. 222-6, deal with guarantees, reparability, spare parts, software updates and delivery options for goods and digital content, and I read them as having little bearing on fund or portfolio marketing.

What the CSSF communication asks for, and what it leaves open

The CSSF text makes two points. The first is general: consumer-facing sustainability-related claims should be clear, accurate and duly substantiated. The second is specific: requirements imposed by law should not be presented as a distinctive sustainability feature. That second point maps onto one line of the new blacklist, point 32 of Article L. 122-4, and it is the only practice the CSSF names.

The communication draws the attention of market participants generally and places its expectations on “financial market participants”, a term it does not define. The definition most readers will reach for is Article 2(1) of the Sustainable Finance Disclosure Regulation (SFDR), which covers, among others, AIFMs, UCITS management companies, investment firms providing portfolio management and credit institutions providing portfolio management. An investment firm that only gives advice or executes orders sits outside that SFDR list. The reach of the Consumer Code is set by its own terms: the rules apply to business-to-consumer commercial practices by any trader, so a broker or adviser with retail clients faces the same blacklist whether or not the CSSF’s wording was aimed at it.

Two questions stay open after reading the communication. It does not say which authority will take enforcement action against financial firms under the Consumer Code, or how the CSSF will fold these consumer-law expectations into its own supervision. The Commission’s Q&A states only that enforcement lies with national competent authorities and courts, and that some national laws allow natural and legal persons to bring proceedings themselves. How that plays out in Luxembourg for a supervised entity is not addressed in either text.

Consumer-facing means business-to-consumer

The Unfair Commercial Practices Directive (UCPD), which the ECGT Directive amends, is strictly limited to business-to-consumer practices; the Commission’s Q&A says so in its first answer and places business-to-business communication outside the harmonised framework. A consumer is a natural person acting for purposes outside their trade, business, craft or profession (Article 2(a) UCPD). A product is any good or service, including rights and obligations (Article 2(c)), which in my reading comfortably covers units in a fund and a portfolio management mandate. A commercial practice is any act, omission, representation or commercial communication, including advertising and marketing, directly connected with the promotion, sale or supply of a product to consumers (Article 2(d)).

For AIFMs, the distribution model sets the exposure. Article 31(6) AIFMD requires AIFs managed and marketed by AIFMs to be marketed only to professional investors, without prejudice to Article 43(1), under which Member States may allow marketing to retail investors in their territory. A manager whose investor base is institutional has a narrow consumer-facing surface. A manager distributing a retail AIF or an ELTIF to individuals has the same surface as a UCITS house. The grey area is the individual who invests private wealth through a professional-investor channel, which the FAQ below takes up.

The definition of an environmental claim excludes any message that is mandatory under Union or national law. Content that the prospectus, the PRIIPs key information document, the SFDR pre-contractual annexes or the periodic reports require is outside the definition to the extent it is mandatory. The Commission applies the same logic to corporate sustainability reporting under the CSRD, which our CSRD sustainability reporting guide covers: such reports are typically out of scope because they are often mandatory and addressed to investors, but the same information falls within the rules once it is reused in voluntary advertising or marketing directed at consumers. On that logic, a sentence copied from an SFDR annex into a retail advert does not carry the annex’s status with it, because the advert is voluntary.

Five blacklisted practices, read against fund and portfolio marketing

Points 28 to 32 of Article L. 122-4 transpose Annex I points 2a, 4a, 4b, 4c and 10a of the UCPD as amended. The remaining new points, 33 to 39, concern software updates, durability, repairs and consumables for goods. The five claim-related points operate without the case-by-case test: a practice that fits the description is unfair without any further assessment of its effect on consumers.

Sustainability labels (point 28)

Point 28 prohibits displaying a sustainability label that is not based on a certification scheme or established by public authorities. A sustainability label is any voluntary trust mark, quality mark or equivalent, public or private, that sets apart a product, process or business for its environmental or social characteristics, or both; mandatory labels are excluded (Article L. 121-2, point 15). Social characteristics are inside the definition, so a social or impact label on a fund is caught as much as a climate one.

A certification scheme has to meet four conditions (point 16). It is open on transparent, fair and non-discriminatory terms to all traders willing and able to comply. Its requirements are developed by the scheme owner in consultation with relevant experts and stakeholders. It sets out procedures for non-compliance, including withdrawal or suspension of the label. And compliance is monitored through an objective procedure by a third party whose competence and independence from both the scheme owner and the trader rest on international, Union or national standards and procedures.

Three details from the Commission’s Q&A matter for anyone displaying a fund label. The scheme owner and the monitoring third party have to be two different legal entities, even where an international standard would allow them to be the same. A label set up by a public authority outside the EU does not benefit from the public-authority route and needs a certification scheme like any private label. And the trader is expected to check the scheme’s publicly available terms before displaying the label; labels that fail the definition have to come out of commercial communications.

A compliant label is still no shield for the text around it. The Q&A notes that a label can itself amount to an environmental claim and stays subject to the rest of the UCPD, precisely so that labels cannot serve as a “safe haven” for misleading claims.

Generic environmental claims (point 29)

Point 29 prohibits a generic environmental claim where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. The definitions carry the weight. An environmental claim is any message or representation, not mandatory under Union or national law, in any form (text, image, graphic, symbol, label, brand name, company name or product name) made in a commercial communication, that states or implies a positive or zero environmental impact, less damage to the environment than other products, brands or traders, or improvement over time (point 13). It becomes generic when it is made in written or oral form, is not part of a sustainability label, and its specification is not given in clear and prominent terms on the same medium (point 14).

Recital 9 of the Directive lists the kind of wording in play: “environmentally friendly”, “eco-friendly”, “green”, “nature’s friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”, “carbon friendly”, “energy efficient”, “biodegradable”, “biobased”. Recognised excellent environmental performance means compliance with the EU Ecolabel under Regulation (EC) No 66/2010, with an officially recognised EN ISO 14024 type I ecolabel, or top environmental performance under other applicable Union law (point 17). The Commission illustrates that route with national ecolabels such as the Nordic Swan and the Blue Angel, EU Ecolabel product groups (textiles, cleaning products, paper and tourist accommodation among them) and energy labels. None of the examples concerns a financial product, and my working assumption is that a fund or a managed portfolio will rarely be able to rely on it. The route that stays open is specification.

The Q&A’s own contrast shows where the line runs. “Climate-friendly packaging” with nothing more is generic; “100% of energy used to produce this packaging comes from renewable sources” is specific and falls outside point 29, although it still has to be accurate and supported. Carried over to fund marketing, a banner line such as “the green choice for your savings” is of the first type, and a statement on the same banner of the measurable investment policy behind the word, consistent with the fund documentation, moves toward the second. The Q&A also repeats the line from the 2021 UCPD Guidance that where there is no space to specify an environmental claim, the claim should generally not be made. Short formats (display ads, social posts, app notifications) are where that sentence bites.

Colour and imagery alone are outside the generic-claim definition, because it requires written or oral form. The Q&A adds that images combined with text can form a generic claim, and that green leaves or similar icons can amount to an implicit claim, or even to a sustainability label, depending on context and consumer perception.

Whole-product claims (point 30)

Point 30 prohibits an environmental claim about the entire product or the trader’s entire business when it concerns only one aspect of the product or a specific activity of the business. Recital 11 describes the target as a claim about the whole when it concerns only a certain aspect or a specific, unrepresentative activity. In a fund range the house-level claim is the exposed one: retail pages describing the management company as environmentally responsible on the strength of a small number of SFDR Article 9 funds inside a much larger range. At product level, a multi-asset fund advertised through its green bond sleeve raises the same question. Both are my readings of the text; neither the recital nor the Commission’s Q&A uses a financial example.

Offset-based neutrality claims (point 31)

Point 31 prohibits claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions. Recital 12 supplies the vocabulary: “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact”, “limited CO2 footprint”. Such claims are allowed only where they rest on the actual lifecycle impact of the product itself.

Two limits run the other way. The Commission’s Q&A states that point 31 does not apply to offsetting claims made at company level, which remain subject to the other UCPD provisions. And Recital 12 says the prohibition does not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, provided the information is not misleading and complies with Union law. A “carbon-neutral portfolio” description that depends on purchased credits reads to me as exactly the product-level claim point 31 was written for.

Legal requirements presented as features (point 32)

Point 32 prohibits presenting requirements imposed by law on all products in the relevant product category on the EU market as a distinctive feature of the trader’s offer. This is the practice the CSSF singled out, and asset management has several sustainability obligations that apply across whole categories:

• Commission Delegated Directive (EU) 2021/1270 has required UCITS management companies, since 1 August 2022, to take sustainability risks into account in their organisational requirements, due diligence and risk management.
• Commission Delegated Regulation (EU) 2021/1255 inserted into Article 18 of Delegated Regulation (EU) No 231/2013 the requirement that AIFMs take sustainability risks into account, applicable from the same date.
• Commission Delegated Regulation (EU) 2021/1253 has required investment firms providing investment advice or portfolio management, since 2 August 2022, to include information on a client’s sustainability preferences, where relevant, in the investment objectives gathered for the suitability assessment.

The CSSF separately expects requirements imposed by law not to be presented as a distinctive sustainability feature. Point 32 is narrower: it concerns requirements imposed by law on all products within the relevant product category on the Union market. Firm-level duties such as sustainability-risk integration or suitability questioning should therefore be assessed against the CSSF expectation and the general misleading-practices rules; they should not be treated as automatically blacklisted under point 32 unless the statutory product-category condition is met. Product-level SFDR rules that apply only to some funds likewise require a separate assessment.

Future-performance and comparison claims: the case-by-case tests

Outside the blacklist, the Luxembourg law extends the general misleading-actions test in Article L. 122-2. That test still turns on whether a practice causes or is likely to cause the average consumer to take a transactional decision they would not otherwise have taken, and the Commission stresses that each case is assessed on its facts.

New letter d) of Article L. 122-2, paragraph 2, covers an environmental claim about future environmental performance made without clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan. The plan has to include measurable, time-bound targets and other elements needed to deliver it, such as allocation of resources, and it has to be regularly verified by an independent third-party expert whose findings are made available to consumers. A net-zero target for a fund range, or a firm-level 2050 commitment repeated in retail marketing, is the obvious candidate. The Q&A fills in the mechanics:

• private auditors or consultancies can act as the expert, provided they are independent from the trader, free from conflicts of interest and competent in environmental matters;
• the Directive fixes no verification interval, and the Q&A describes annual or biennial reviews as best practice, with extra verification after significant changes;
• the plan and the expert’s findings can sit on the trader’s website, reached for example through a QR code, without being reproduced on the same medium as the claim.

New letter e) covers advertising benefits for consumers that are irrelevant and do not result from any feature of the product or business. The Q&A reads the two conditions as cumulative. A benefit shared by most products in a category is not automatically misleading if it is genuinely relevant to the product.

New paragraph 8 of Article L. 122-3 applies where a professional provides a service that compares products on environmental or social characteristics or circularity aspects. The comparison method, the products compared, their suppliers and the measures in place to keep that information up to date become material information. A distribution platform or app that lets retail clients rank funds by a sustainability score looks to me like such a service, and leaving out the method then becomes a candidate misleading omission.

Environmental and social characteristics now appear expressly among the main characteristics about which a practice can mislead (Article L. 122-2, paragraph 1, point 2), letter b)). Social claims about a fund are therefore tested case by case, even though the generic-claim ban in point 29 covers environmental claims only.

Behind all of this sits Article 12 of the UCPD. It requires Member States to give courts or administrative authorities the power to require a trader, where appropriate in the circumstances of the case, to furnish evidence of the accuracy of factual claims in a commercial practice, and to treat those claims as inaccurate if the evidence is not furnished or is insufficient. The CSSF’s “duly substantiated” wording points at the same evidence file.

SFDR, fund names and MiFID II keep running alongside

The sector rules that already govern fund and investment-firm marketing stay in place. SFDR Article 13(1) requires financial market participants and financial advisers to ensure that marketing communications do not contradict the information disclosed under SFDR, without prejudice to stricter sectoral legislation. MiFID II Article 24(3) requires all information, including marketing communications, addressed by an investment firm to clients or potential clients to be fair, clear and not misleading. Our note on the ESMA common supervisory action on MiFID II sustainability preferences covers what supervisors found on the suitability side of sustainability-related conduct rules.

ESMA’s Guidelines on funds’ names using ESG or sustainability-related terms (ESMA34-1592494965-657, dated 21 August 2024) apply to UCITS management companies and AIFMs, among others. ESMA states that they are based on Article 69(6) of the UCITS Directive, Article 23(7) of AIFMD and Article 16(1) of Regulation (EU) No 1095/2010, and that they apply in relation to Article 14(1)(a) of the UCITS Directive, Article 12(1)(a) of AIFMD and Article 4(1) of Regulation (EU) 2019/1156. They set an 80% threshold of investments meeting the environmental or social characteristics or sustainable investment objectives, with Paris-aligned Benchmark exclusions for environmental, impact and sustainability terms and Climate Transition Benchmark exclusions for transition, social and governance terms. Article 69(6) of the UCITS Directive and Article 23(7) of AIFMD were both inserted by Directive (EU) 2024/927 of 13 March 2024, before the guidelines were issued; they mandate ESMA guidelines on when a UCITS or AIF name is unfair, unclear or misleading and state that sectoral legislation setting standards for fund names or marketing of funds takes precedence over those guidelines. For AIFs and ELTIFs, the notification route in our note on the CSSF AIF and ELTIF marketing notification is a separate channel again, and nothing in the ECGT communication changes it.

The UCPD’s conflict rule in Article 3(4) gives specific Union rules priority where they conflict with it on a particular aspect of unfair commercial practices, and the Commission describes the UCPD as a horizontal safety net that complements sector law without taking precedence over it. Conflict is the operative word. SFDR, MiFID II and the fund names guidelines do not address whether “green” on a retail banner needs specification on the same medium, so on my reading the Consumer Code answer is additional to the sector answer.

That matters most for ESG-named funds. Meeting the 80% threshold and the benchmark exclusions supports the substance behind the name. The Commission’s Q&A says separately that product names can be environmental claims, assessed case by case, and that terms such as “green”, “eco” or “climate neutral” used in a name in a way likely to create an environmental association need specification in clear and prominent terms on the same medium; without it, the name is a generic claim. The Q&A also says that “green” or “blue” in a name does not automatically constitute an environmental claim where, in context, consumers are unlikely to expect an environmental benefit. I treat the same-medium check as a separate test to run on every retail communication that carries such a name.

One source of confusion is worth clearing. The Green Claims Directive proposal, which would have added ex ante substantiation and verification rules, is a different instrument. The Commission announced on 20 June 2025 that it intends to withdraw it, and the European Parliament’s legislative train lists the file as blocked. The rules that apply on 27 September 2026 are the ECGT amendments to the UCPD and the Consumer Rights Directive, as transposed in the Consumer Code.

A claims inventory that can be evidenced

The CSSF’s two expectations translate into one review pass across retail-facing material. The Code prescribes no method; the sequence below is how I would order the work against the texts above.

1. Scope the channels that reach consumers: retail web pages, factsheets and brochures, advertising, social media, app content, newsletters, and material supplied to distributors for retail use. Mandatory documents stay outside the claim definition to the extent their content is mandatory.
2. Tag every sustainability term, image, logo, target and ranking in that material: generic environmental claim, specified environmental claim, social claim, sustainability label, future-performance claim, offset-based claim, legal requirement presented as a feature, comparison service.
3. For each generic environmental claim, add the specification on the same medium or remove the claim. For each label not set up by a public authority in the EU, file the certification-scheme test against the four criteria, including the separate-entity point. For each future-performance claim, link the implementation plan and the independent expert’s latest findings.
4. Check each surviving claim against the SFDR disclosures for the same product (Article 13) and, for ESG-named funds, against the fund names thresholds.
5. Keep the evidence per claim, in the form a court or authority could ask for under Article 12 of the UCPD.

Material that distributors write from fund documentation is the part the communication leaves untouched. The Consumer Code attaches to the trader engaging in the commercial practice, and the CSSF text does not say how responsibility for a retail claim splits between a management company that supplied the wording and the distributor that published it.

Frequently Asked Questions

Are individuals classified as professional clients treated as consumers under the new rules?

The consumer definition turns on purpose: a natural person acting outside their trade, business, craft or profession (Article 2(a) UCPD). MiFID II client categories are built on different criteria, and an individual treated as a professional client on request can still be investing private wealth. My reading is that the MiFID categorisation does not by itself take such a person outside the consumer definition, which matters for AIFMs that market only to professional investors. Neither the CSSF communication nor the Commission’s Q&A addresses the point.

Our group has a public net-zero commitment. Can the Luxembourg management company repeat it on its retail website?

Letter d) of Article L. 122-2, paragraph 2, attaches to the claim as made. If the management company repeats the group target in consumer-facing material, the question is whether a detailed and realistic implementation plan with measurable, time-bound targets stands behind that statement as worded, and whether an independent expert verifies it regularly with findings available to consumers. A group plan can serve if it covers what the claim says. A plan limited to the group’s own operations does not, on my reading, support a statement about the portfolios the funds hold.

Is “our operations are carbon neutral” caught by the offsetting ban?

The Commission’s Q&A says point 31 targets product-level claims and does not apply to offsetting at company level. The statement remains exposed elsewhere: an unspecified “carbon neutral” is a generic environmental claim, prohibited under point 29 unless recognised excellent environmental performance relevant to the claim can be shown, and it must still pass the case-by-case misleading-actions test.

We market the same fund in several Member States. Is the Luxembourg Code the only reference?

Each Member State transposes the Directive into its own consumer law, and the Law of 9 June 2026 amends only the Luxembourg Consumer Code. The CSSF communication does not address cross-border marketing. The same retail material may therefore be read against more than one national text, each derived from the same Directive wording but enforced through national procedures.

What happens to brochures and web pages published before 27 September 2026?

The Commission’s Q&A says the rules apply from 27 September 2026 to existing products as well, and that enforcers may consider whether traders made reasonable and proportionate efforts to comply, including for products already in the distribution chain; national authorities in the Consumer Protection Cooperation Network have prepared a common understanding on such “old stock” situations. Those examples concern packaged goods. For a financial firm the analogue is printed brochures still held by distributors and archived pages still reachable online, and the CSSF communication says nothing specific about them.

Does a social-impact fund escape the new rules because point 29 covers only environmental claims?

Point 29 is limited to environmental claims, but a social-impact fund stays exposed on two fronts. Sustainability labels cover social characteristics, so point 28 applies to any social label displayed. And the misleading-actions test now lists social characteristics among a product’s main characteristics; Recital 3, quoted in the Q&A, describes them broadly, from working conditions and human rights to equal treatment and contributions to social initiatives.

Related Articles

• CSSF SFDR FAQ Update: When Template Changes Need Sign-Off: which changes to Article 8 and 9 pre-contractual templates need prior CSSF approval, including fund-name changes aligned with the ESMA guidelines.
• MiFID II Sustainability Preferences: What the ESMA Common Supervisory Action Results Mean for Investment Firms: the May 2026 findings on questionnaire design, record-keeping and product governance.
• CSSF AIF and ELTIF Marketing Notification: What Luxembourg AIFMs Must File: the notification a Luxembourg AIFM files to market EU AIFs or ELTIFs at home or cross-border.
• CSRD Sustainability Reporting: What Luxembourg Entities Need to Know: post-Omnibus scope, timelines and Luxembourg transposition status for mandatory sustainability reporting.

Key Takeaways

• Sunday 27 September 2026 is the first day points 28 to 32 of Article L. 122-4 bite; retail material live that weekend is judged under them.
• Before displaying any fund label that was not set up by a public authority in the EU, confirm from the scheme’s public terms that the owner and the monitoring body are two separate legal entities.
• Where a retail format has no room to specify “green”, “eco” or “climate friendly”, the Commission’s guidance points to dropping the word.
• Sustainability-risk integration is a legal duty for UCITS management companies and authorised AIFMs subject to the relevant organisational rules, while MiFID II suitability rules impose sustainability-preference requirements on investment firms providing investment advice or portfolio management. Do not present an applicable legal duty as a distinctive sustainability feature.
• A consumer-facing net-zero claim about future environmental performance should be supported by a detailed and realistic implementation plan containing clear, objective, publicly available and verifiable commitments and measurable, time-bound targets, with regular verification by an independent third-party expert whose findings are available to consumers.
• For ESG- or sustainability-related fund names, ESMA’s 80% threshold is only one part of the test: apply the term-specific exclusions and any additional criteria in paragraphs 16 to 21 of the Guidelines; separately apply the Consumer Code same-medium specification test where the name constitutes an environmental claim.
• A comparison service shown to consumers that compares funds on environmental or social characteristics or circularity aspects must provide the products compared and their suppliers, the comparison method and the measures used to keep that information up to date; omission of material information is misleading where the transactional-decision test is met.

Sources and References

• Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition (OJ L, 2024/825, 6.3.2024): https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng
• Loi du 9 juin 2026 portant modification du Code de la consommation en vue de la transposition de la directive (UE) 2024/825, Memorial A No 283 of 9 June 2026: https://data.legilux.public.lu/filestore/eli/etat/leg/loi/2026/06/09/a283/jo/fr/pdfa/eli-etat-leg-loi-2026-06-09-a283-jo-fr-pdfa.pdf
• CSSF, Communication on the entry into application of the new rules introduced by Directive (EU) 2024/825 as from 27 September 2026 (23 September 2026): https://www.cssf.lu/en/2026/09/communication-on-the-entry-into-application-of-the-new-rules-introduced-by-directive-eu-2024-825-as-from-27-september-2026/
• European Commission, Questions and Answers on Directive (EU) 2024/825 (September 2026): https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=faq-empowerting-consumers-gtd.pdf
• Directive 2005/29/EC on unfair business-to-consumer commercial practices (UCPD), consolidated text applicable from 27 September 2026, CELEX 02005L0029-20260927: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02005L0029-20260927
• Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR): https://eur-lex.europa.eu/eli/reg/2019/2088/oj/eng
• Directive 2014/65/EU on markets in financial instruments (MiFID II): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0065
• Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0061
• Directive (EU) 2024/927 amending Directives 2011/61/EU and 2009/65/EC: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202400927
• Commission Delegated Directive (EU) 2021/1270 of 21 April 2021 as regards sustainability risks and sustainability factors for UCITS: https://eur-lex.europa.eu/eli/dir_del/2021/1270/oj/eng
• Commission Delegated Regulation (EU) 2021/1255 of 21 April 2021 as regards sustainability risks and sustainability factors for AIFMs: https://eur-lex.europa.eu/eli/reg_del/2021/1255/oj/eng
• Commission Delegated Regulation (EU) 2021/1253 of 21 April 2021 as regards the integration of sustainability factors, risks and preferences for investment firms: https://eur-lex.europa.eu/eli/reg_del/2021/1253/oj/eng
• ESMA, Guidelines on funds’ names using ESG or sustainability-related terms, ESMA34-1592494965-657 (21 August 2024): https://www.esma.europa.eu/sites/default/files/2024-08/ESMA34-1592494965-657_Guidelines_on_funds_names_using_ESG_or_sustainability_related_terms.pdf
• ESMA, press release on harmonised criteria for ESG and sustainability terms in fund names (14 May 2024): https://www.esma.europa.eu/press-news/esma-news/esma-guidelines-establish-harmonised-criteria-use-esg-and-sustainability-terms
• European Parliament, Legislative Train Schedule, Substantiating and communicating green claims: https://www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-substantiating-green-claims

Before the Consumer Code Rules Apply on 27 September

The CSSF’s reminder came four days before a date the Directive set in 2024 and the Luxembourg law confirmed in June. The artifact to have by Sunday 27 September 2026 is a claims register covering every retail-facing channel, listing each sustainability term, label, target and ranking with its same-medium specification, its certification-scheme or verification evidence and its SFDR cross-check, with every claim that cannot be supported taken down before the Consumer Code applies.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.