From Boardrooms to Courtrooms: The Constitutionality of Anti-ESG Regulations

Saanvi Siddhi

Edited by Jordan Perlman, Luis Carvajal Picott, Judge Baskin, and Sahith Mocharla

Once confined to company boardrooms and niche financial forums, sustainable investment and disclosure have become state policy, fundamentally altering how billions in public funds are managed. When states end up determining which investment philosophies are acceptable, economic freedom becomes inseparable from political conformity. Investing strategies once deemed neutral, together with ostensibly financial tactics, have increasingly been appropriated as instruments to advance political objectives. This politicization of investment strategy has given rise to anti-ESG legislation: state policies that discourage the use of environmental, social, or governance criteria in financial decision making. Anti-ESG laws not only unconstitutionally undermine economic efficiency but also weaponize state contracts to punish disfavored viewpoints. In the process, they undermine free market principles, burden interstate commerce, and create a fragmented national market. Ultimately, this puts the U.S. at a disadvantage in an increasingly sustainability-driven global economy.

ESG investing is a strategy used by asset managers and investors that analyzes a company's performance and its long-term risks in the non-financial pillars of environmental, social, and governance (ESG) criteria [1]. The prioritization of the ESG pillars is meant to promote sustainable and ethical business practices while still valuing potential financial returns. These three pillars cover various aspects of corporate behavior, from energy efficiency and labor standards to political contributions [2]. 

The environmental pillar encompasses the company’s impact on the ecosystem and planet. Company policies centered around this might include transitioning to renewable energy sources or adopting more sustainable product design. Microsoft, for example, committed in 2020 to being carbon negative, zero waste, and water positive by the year 2030 [3]. The social pillar of ESG focuses on how company policies affect people, specifically employees and surrounding communities [4]. This might include DEI policies, maintaining labor standards, and community engagement. The final governance pillar pertains to the ethical standards that are maintained for a company’s operations [5]. This includes data protection, transparent operations, and anti-corruption measures. As anti-ESG legislation continues to garner steam, it becomes increasingly clear that the social pillar is at the center of their political bullseye; as its policies have become especially controversial recently due to ongoing debates regarding corporate involvement in political and social issues. 

While the term ESG was first coined in 2004, anti-ESG laws entered a larger debate beginning in 2021, following the introduction of such legislation in states like Iowa, Minnesota, and Ohio [6]. These actions came directly in response to Biden-era attempts to protect the federal financial system against risks stemming from the climate crisis. The attempt in question was finalized by the Department of Labor in 2022 and allowed retirement fund managers to consider risks posed by climate change when making investments [7]. Since then, across the country, anti-ESG laws have become a tool wielded by (primarily) Republican or Conservative lawmakers to limit so-called “woke capitalism” [8]. These lawmakers argue that ESG investing unfairly pushes policy and social agendas over financial goals, and that ESG policies have detrimental impacts on local economies. However, the first part of these claims has been substantially debunked by a McKinsey study published in 2023 which showed that businesses that prioritize ESG policies on top of their normal operations have been found to add shareholder value for their company and outperform their competitors in both growth and profitability [9]. Other proponents of ESG policies, including BlackRock CEO Larry Fink, argue that they are common-sense policies that make for good investing, since things like climate risk are inherently also financial risks [10]. This idea is demonstrated in both physical risks, such as damages from natural disasters, and transition risks, which include losses in the fossil fuel and utilities sectors as the economy shifts toward clean energy. Currently, 22 states have implemented 56 anti-ESG laws, including Texas, Florida, and North Carolina [11]. While the number of anti-ESG policy proposals has grown exponentially in recent years, support for them continues to decline as, despite continued national fervor, only a fraction of these policies actually pass [12].

There are two main types of anti-ESG legislation. The first type, known as anti-ESG investment fiduciary laws, restricts how states make investment decisions. These restrictions target either state pension funds or public investment managers who oversee investments for government entities such as cities and states and prevent them from considering ESG factors [13]. An example of this type of regulation would be Florida House Bill 3 (2023), which requires all state and local investment decisions and procurement processes to be “based solely on pecuniary factors…expected to have a material effect on the risk or returns of an investment” [14]. The bill also prohibits giving preference to vendors based on consideration of any “social, political, or ideological interests” [15]. Florida’s HB 3 has proven to be one of the most restrictive anti-ESG legislations of its kind. Even laws in Arkansas and Montana allow for ESG considerations if they demonstrably affect risk and return [16]. The Florida law has completely redefined a qualified public depository in the state and significantly narrowed fiduciary discretion. 

The second type of anti-ESG laws are boycott regulations. Boycott regulations bar financial institutions that use ESG criteria from discriminating against companies in specific industries, particularly ones important to the local economy [17]. These boycott regulations prohibit the state from doing business with said financial institutions or using these institutions to invest state assets. The local energy industry in Texas is a $172 billion industry and employs more than 50,000 people in the state, making it especially vulnerable to investment approaches that penalize fossil-fuel firms [18]. Under Texas Senate Bill 13 (2021)––one of the country's largest anti-ESG measures––the state comptroller is required to maintain a list of the financial companies that “boycott certain energy companies” (i.e., fossil fuel companies) [19]. The law prohibits state agencies from either investing in or contracting with such financial institutions; it also mandates that they immediately divest from them. These policies are also somewhat coercive when it comes to financial institutions. Following SB 13, BlackRock, the world's largest asset manager, had billions of funds that it managed for the state pulled away [20]. Only after BlackRock withdrew from two climate organizations was it allowed to do business with the state again [21]. 

Anti-ESG legislation affects everything from the economy to politics. In a 2023 study conducted by Brookings on the financial costs of anti-ESG policies, researchers found reduced competition in the public finance market. As a result, interest costs were 0.144% higher [22]. Therefore, Texas cities paid anywhere from $303 million to $532 million more interest on $32 billion of bonds issued during the first eight months after Texas Senate Bills 13 and 19 went into effect [23]. These effects reverberate beyond short-term borrowing costs as they risk reducing capital inflows, discouraging innovation, and increasing long-term financing constraints for transitioning industries like renewable energy. Additionally, in the aftermath of the implementation of anti-ESG laws in Texas, in fiscal years 2022 and 2023, Texas lost around $669 million in economic activity, as well as $181 million in decreased annual earnings, 3,034 fewer full-time jobs, and more than $37 million in tax revenues [24]. These kinds of economic contractions increase dependence on federal transfers and undercut Texas’s narrative of self-reliant, market-driven growth. These economic effects were found to come directly after the implementation of Texas’s anti-ESG legislation as five of the state's largest municipal underwriters exited the state's market, resulting in less competition, higher borrowing costs, and reduced transparency in pricing [25]. Texas has long been a state characterized by its business-friendly climate. Low taxes, (intentionally) lax regulations, and its laissez-faire approach to how individuals and firms choose to conduct their business make it the perfect marketplace for many companies. However, the implementation of anti-ESG laws in the state is a contradiction that undermines free-market principles by imposing ideological limits on financial decision-making and discourages market competition under the guise of protecting state interests.

Along with the detrimental economic effects of such legislation, like increased interest costs and fewer jobs, a partisan aspect is intrinsically linked with the overall politicization of markets. This is especially true with red and blue states having such drastically different approaches to ESG legislation. States like California and Maryland require consideration of ESG factors in investment decisions when it comes to the management of government assets and public pension funds [26]. A depository institution is any financial entity that accepts deposits and offers services like loans and payments, for example banks and credit unions. In Connecticut, these institutions are required to disclose their policies toward industries that are considered unfavorable under ESG standards and mandates that the state actively consider those policies when handing out state contracts [27]. These divergences between pro- and anti-ESG states fragment the national marketplace and create uncertainty for investors who operate across state borders.

Regardless of economic effects, anti-ESG laws have drawn backlash for being unconstitutional on multiple fronts. The First Amendment's Freedom of Speech Clause prohibits the government from creating laws “abridging the freedom of speech” [28]. This protection extends not only to overt restrictions on speech but also to content-based discrimination of speech. Viewpoint discrimination is a type of content discrimination wherein one type of speech is singled out and disallowed, despite other viewpoints of the same subject matter being permitted [29]. In other words, while encompassing content discrimination is legal, specific viewpoint discrimination is not. A principle was upheld in the case of Rosenberger v. Rector and Visitors of UVA (1995) [30]. In this case, the Supreme Court ruled that the public University of Virginia violated the First Amendment when it denied funding to a student publication because it promoted a Christian perspective while still funding other secular publications. The Court held that this action constituted viewpoint discrimination as it engaged in favoritism toward certain ideas over others, reaffirming that the government cannot suppress speech––even if it disagrees with the viewpoint expressed. Similarly, anti-ESG laws are in violation of this principle because they penalize financial firms that choose to distance themselves from industries like fossil fuels or that support ESG-focused investment standards. Meanwhile they allow firms that take the opposite viewpoint to operate freely and without consequence and in doing so, they echo the same unconstitutional bias that was condemned in Rosenberger.

Additionally, as established in the case of Board of County Commissioners v. Umbehr (1996), independent government contractors, like public employees, are protected under the First Amendment from termination or retaliation based on their political speech or viewpoints [31]. The case involved a contractor whose county waste-hauling contract was canceled after he criticized the county board. The Court ruled that such retaliation constituted a violation of free speech protections because it conditioned access to government contracts on political conformity. This case stands in direct contrast to anti-ESG laws, which clearly condition access to state business on the suppression of a disfavored viewpoint. Beyond prohibiting discrimination, the First Amendment also protects Americans from compelled speech. The compelled speech doctrine states that the government cannot force an individual or group to express a certain opinion, and cannot condition benefits based on agreeing to or disclaiming a certain viewpoint [32]. This is directly relevant to laws such as Texas’s SB 13, which requires a statement from companies to certify that they do not “boycott energy companies” in order to be eligible for the state's business [33]. By mandating such certifications, the state is compelling speech and enforcing ideological conformity as a prerequisite for participation in public commerce. Requiring firms to disavow ‘boycotts’ of fossil fuel companies effectively coerces them into adopting the state’s preferred political and economic stance. 

Under Article 1, Section 8 of the Constitution, the Dormant Commerce Clause bars state laws that unjustly restrict interstate commerce or discriminate against out-of-state parties [34]. Even if a law is not discriminatory at face value, it can still be deemed unconstitutional if it creates an “undue burden” on interstate commerce, ie. when the negative economic impacts on interstate trade outweigh the local benefits [35]. First defined in the 1970 case of Pike v. Bruce Church, Inc., when the Supreme Court struck down an Arizona law requiring cantaloupes grown in the state to be packaged locally before being shipped out of state. The law placed a significant economic burden on the farmer, who would need to build a new facility solely to comply with the regulation, even though the state’s benefit from promoting the Arizona label on its produce was minimal [36]. Going back to a previous example, Florida House Bill 3 illustrates how anti-ESG laws can violate the Pike balancing principle. HB 3 requires that depository institutions holding public Florida funds not deny services to any person, including those out of state, based on ESG factors [37]. This effectively regulates out-of-state commerce, since banks may have to alter their practices nationwide to remain eligible for Florida contracts. In Pike, the law creates a substantial burden on interstate commerce, as it compels financial institutions to conform their operations across all states with Florida’s anti-ESG stance, a costly and time-consuming process [38]. Conflicts arise when states like California take the opposite approach. For example, California's SB 185 law in 2015 required the divestiture of state funds from thermal coal companies and prohibited new investments in such companies. This makes compliance with Florida laws for firms practically impossible [39]. This legal dichotomy shows how conflicting state-level ESG and anti-ESG laws create a splintered national marketplace that undermines the constitutional goal of a unified economic system.

Many state-wide anti-ESG laws risk being preempted because they conflict with established federal regulatory frameworks. This idea is derived from the Supremacy Clause, found in Article 6 of the Constitution, which states that federal law supersedes state law [40]. The National Securities Markets Improvement Act of 1996 (NSMIA) prohibits states from directly or indirectly prohibiting, limiting, or imposing conditions on the sale of exchange-listed securities or mutual funds based on perceived merits [41]. And so, Boycott regulations may violate NSMIA by restricting the sale or purchase of securities, based on politically biased judgments that ESG-related investments lack merit. In addition to NSMIA, the Employee Retirement Income Security Act of 1974 (ERISA) also precedes state laws. ERISA requires fiduciaries to act “solely in the interest” of beneficiaries and recently, the Department of Labor passed a rule stating that ESG factors can be considered in investment decisions if they are financially relevant [42]. As such, state anti-ESG statutes, such as Florida’s HB 3, directly conflict with ERISA and may therefore be invalidated on preemption grounds. If the Supremacy Clause were applied in this context, it would mean that federal law would override both conflicting state anti-ESG regulations as well as certain pro-ESG mandates. This would ensure a more uniform national framework for the scope of fiduciary duty and securities regulation. 

These arguments were recently used to strike down two anti-ESG rules in Missouri in the case of Securities Industry and Financial Markets Association (SIFMA) v. Ashcroft, which was decided in 2024. In this case, SIFMA, a trade association, sued the attorney general of Missouri over two rules that required securities firms and professionals to obtain signed consent forms from investors before incorporating any “social” or other “non-financial” objectives into their investment advice or recommendations [43]. These forms forced investors to acknowledge that such advice would lead to investments “not solely focused on maximizing financial returns,” effectively discouraging the integration of ESG considerations [44]. However, using ERISA and NSMIA, the federal court ruled that Missouri’s disclosure requirements were preempted by federal law and violated the First Amendment’s protections against compelled speech. Additionally, the federal court also found that the mandated consent statements controversially and unnecessarily compelled speech, since it forced firms and investors to convey the state's political message that ESG investing is not inherently relevant to fiduciary duty [45]. This case has been vital in showing that challenges to anti-ESG regulations have legal backing and has already been used as a reference in other challenges to anti-ESG legislation such as Oklahoma's HB 2034.

While the U.S. has taken a largely state-driven approach to ESG policy, overseas, the Sustainable Finance Disclosure Regulation (SFDR) adopts a more centralized framework. This E.U. law mandates ESG disclosure for financial market participants and has been in effect since 2021 [46]. The SFDR is meant to integrate sustainability into financial decision-making and has had a positive impact preventing greenwashing in sustainability reports, streamlining ESG data processes, and resulting in greater buy-in for ESG [47]. In order for U.S. companies to interact with E.U. markets, whether they are trying to sell or reside there, they too must abide by SFDR regulations. This includes strict disclosure mandates and integrating sustainability considerations into their operations [48]. The E.U. is not the only one creating national frameworks around ESG investing. China has set nationwide goals when it comes to environmental policies like carbon neutrality, has increased investment into renewable energy, and, under the China Securities Regulatory Commission, has worked to increase sustainability disclosure [49]. These international frameworks illustrate how global markets are rapidly aligning around sustainability-focused financial systems, while the United States risks falling behind.

In the absence of a federal ESG framework, individual states have taken conflicting approaches to regulating sustainable finance. Some states, such as California and New York, have advanced pro-ESG disclosure or investment standards, while others, including Texas and Florida, have enacted anti-ESG statutes that restrict the use of non-financial criteria in investment decisions. This patchwork of state policies complicates compliance for national firms, and raises conflicts with federal laws that aim to coordinate financial and fiduciary standards nationwide. The rise of anti-ESG legislation across the country is symbolic of a larger disunity over the intersection of both politics and economics. By penalizing certain investment philosophies, anti-ESG laws decrease competition, restrict free speech and interstate commerce, and, when combined with pro-ESG legislation, splinter the national marketplace.

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[1] Department of Financial Protection and Innovation, Embracing Sustainable Investment Practices with ESG Investing, CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION (Apr. 2025), https://dfpi.ca.gov/news/insights/embracing-sustainable-investment-practices-with-esg-investing/.  

[2] CFA Inst., What Is ESG Investing?, CHARTERED FINANCIAL ANALYST INSTITUTE (Mar. 4, 2024), https://www.cfainstitute.org/insights/articles/what-is-esg-investing.  

[3] Corporate Responsibility, Advancing Sustainability, MICROSOFT, https://www.microsoft.com/en-us/corporate-responsibility/sustainability. 

[4] See [2]. 

[5] Corporate Governance Institute, Three Pillars of ESG: Ultimate Guide to ESG, CORPORATE GOVERNANCE INSTITUTE (Feb. 15, 2023), https://www.thecorporategovernanceinstitute.com/insights/lexicon/three-pillars-of-esg-ultimate-guide-to-esg/. 

[6] IBM Think, The History of Environmental, Social and Governance (ESG), INTERNATIONAL BUSINESS MACHINES], https://www.ibm.com/think/topics/environmental-social-and-governance-history. 

[7] U.S. Dep’t of Labor Employee Benefits Security Admin., Final Rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights, U.S. DEP’T OF LABOR (Nov. 22, 2022), https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/fact-sheets/final-rule-on-prudence-and-loyalty-in-selecting-plan-investments-and-exercising-shareholder-rights. 

[8] CNBC, Bank CEO Shrugs Off U.S. “War on ‘Woke’ Capital,” Says ESG Investing Is Good for Business, CONSUMER NEWS AND BUSINESS CHANNEL (Feb. 27, 2024), https://www.cnbc.com/2024/02/27/war-on-woke-capitalism-stanchart-ceo-says-esg-is-good-for-business.html. 

[9] Strategy & Corporate Finance Team, The Triple Play: Growth, Profit, and Sustainability, MCKINSEY & COMPANY (Aug. 9, 2023), https://www.mckinsey.com/capabilities/strategy-and-corporate-finance/our-insights/the-triple-play-growth-profit-and-sustainability. 

[10] MSN Money, BlackRock Is Off Texas Blacklist—Where the ESG Battle Stands Now, MICROSOFT NETWORK (Mar. 1, 2024), https://www.msn.com/en-us/money/markets/blackrock-is-off-texas-blacklist-where-the-esg-battle-stands-now/ar-AA1G64Ky. 

[11] Pleiades Strategy, Live Anti-ESG State Action Tracker, PLEIADES STRATEGY, https://www.pleiadesstrategy.com/pleiades-anti-esg-bill-tracker-state-legislation-attacks-on-responsible-investing. 

[12] Jeremy Ho, Anti-ESG Proposals Have Increased in Volume, but Fare Poorly, HARVARD. LAW SCHOOL FORUM ON CORPORATE GOVERNANCE (Feb. 6, 2025), https://corpgov.law.harvard.edu/2025/02/06/anti-esg-proposals-have-increased-in-volume-but-fare-poorly/. 

[13] Bruno Bischoff, Anti-ESG Legislation in the USA: Emerging Risk for Financial Institutions?, ECOFACT (Dec. 13, 2022), https://www.ecofact.com/de/blog/anti-esg-legislation-in-the-usa/. 

[14] Florida House of Representatives, CS/CS/HB 3 (2023), An Act Relating to Government and Corporate Activism, FLA. LEGISLATURE (2023), https://www.flsenate.gov/Session/Bill/2023/3/BillText/er/PDF. 

[15] See [14]. 

[16] Leah Malone & Emily B. Holland, Florida Passes Farthest-Reaching Anti-ESG Law to Date, HARVARD. LAW SCHOOL FORUM ON CORPORATE GOVERNANCE (May 27, 2023), https://corpgov.law.harvard.edu/2023/05/27/florida-passes-farthest-reaching-anti-esg-law-to-date/. 

[17] See [13]. 

[18] Texas EDC, Texas Energy Sector • Texas Energy Industry, TEXAS ECONOMIC DEVELOPMENT CORPORATION, https://www.businessintexas.com/business-sectors/energy/. 

[19] Texas Senate Bill No. 13, 87th Leg., R.S., ch. 809 & 2274, 2021 Tex. Gen. Laws (effective Sept. 1 2021), https://capitol.texas.gov/tlodocs/87R/billtext/html/SB00013F.HTM. 

[20] See [10]. 

[21] See [10]. 

[22] Daniel G. Garrett & Ivan T. Ivanov, Gas, Guns, and Governments: Financial Costs of Anti-ESG Policies, BROOKINGS INSTITUTE (Apr. 12, 2023), https://www.brookings.edu/articles/gas-guns-and-governments/. 

[23] Angie Basiouny, Texas Fought Against ESG. Here’s What It Cost, KNOWLEDGE AT WHARTON (July 12, 2022), https://knowledge.wharton.upenn.edu/podcast/knowledge-at-wharton-podcast/texas-fought-against-esg-heres-what-it-cost/. 

[24] TXP, Inc., The Potential Economic and Tax Revenue Impact of Texas’ Fair Access Laws (Winter 2024), TEX. ASS’N OF BUS. (Winter 2024), https://cb9cdd3c-61f1-494f-94da-c77c057de62c.usrfiles.com/ugd/cb9cdd_3abaf3cce79c4dc4a23ec1bc6d3a4ad0.pdf. 

[25] Hund et al. Do Anti-ESG Policies Hurt Local Governments? Evidence from the Municipal Bond Market, SOCIAL SCIENCE RESEARCH NETWORK (Jun. 13, 2025), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5287090. 

[26] Babyak et al. An Analysis of the Constitutionality of State ESG Laws COMMITTEE ON CAPITAL MARKETS REGULATION (Oct. 2024), https://capmktsreg.org/wp-content/uploads/2024/10/CCMR-Analysis-of-the-Constitutionality-of-State-ESG-Laws-10-07-24-Final.pdf. 

[27] See [26]. 

[28] U.S. NAT’L ARCHIVES & RECORDS ADMIN., The Bill of Rights: A Transcription, NAT’L ARCHIVES (Aug. 7, 2025), https://www.archives.gov/founding-docs/bill-of-rights-transcript. 

[29] Kevin Francis O’Neill, Viewpoint Discrimination, FREE SPEECH CENTER (Aug. 10, 2023), https://firstamendment.mtsu.edu/article/viewpoint-discrimination/. 

[30] Hudson Jr., David L., “Supreme Court Case: Matal v. Tam (2017) – Oyez”, OYEZ (1994), https://www.oyez.org/cases/1994/94-329. 

[31] Rosenberger v. Rector & Visitors of the University of Virginia, OYEZ (1995), https://www.oyez.org/cases/1995/94-1654. 

[32] David L. Hudson Jr., Compelled Speech, FIRST AMENDMENT ENCYCLOPEDIA (Jul. 31, 2023), https://firstamendment.mtsu.edu/article/compelled-speech/.

[33] See [19]. 

[34] U.S. Const. art. I, § 8, cl. 3 tbl., CONGRESS.GOV, https://constitution.congress.gov/browse/essay/artI-S8-C3-7-1/ALDE_00013307/. 

[35] See [26]. 

[36] Pike v. Bruce Church, Inc., 397 U.S. 137 (1970) https://supreme.justia.com/cases/federal/us/397/137/. 

[37] See [14]. 

[38] See [26]. 

[39] Cal. S.B. 185, 2023 Reg. Sess., LegiScan, https://legiscan.com/CA/text/SB185/id/1114407. 

[40] U.S. Const. art. VI, cl. 2, CONGRESS.GOV, https://constitution.congress.gov/browse/essay/artVI-C2-1/ALDE_00013395. 

[41] National Defense Authorization Act for Fiscal Year 1996, Pub. L. No. 104-290, 110 Stat. 3405 (1996), https://www.congress.gov/104/plaws/publ290/PLAW-104publ290.pdf. 

[42] See [26]. 

[43] Missouri Secretary of State, 15 CSR 30-51, MISSOURI CODE OF STATE REGULATIONS, https://www.sos.mo.gov/cmsimages/adrules/csr/current/15csr/15c30-51.pdf

[44] Rebecca Keegan, The Anti-ESG Movement Has Not Fared Well in Court, but Critical Decisions Are Pending, COLUM. L. SCH. BLOG ON CLIMATE CHANGE (Oct. 25, 2024), https://blogs.law.columbia.edu/climatechange/2024/10/25/the-anti-esg-movement-has-not-fared-well-in-court-but-critical-decisions-are-pending/. 

[45] See [44]. 

[46] KPMG Our Insights, What Is the SFDR? KPMG (Sep. 03, 2021), https://kpmg.com/ie/en/insights/esg/what-is-the-sfdr-sustainable-futures.html. 

[47] KPMG Our Insights, Unpacking Sustainable Finance Disclosure Regulation, KPMG (2023), https://kpmg.com/xx/en/our-insights/esg/unpacking-sustainable-finance-disclosure-regulation.html. 

[48] Caroline Pittard, What U.S. Companies Need to Know About SFDR and Its Implications on Transatlantic Investment Strategies, GLOBAL REAL ESTATE SUSTAINABILITY BENCHMARK (Apr. 2023), https://www.gresb.com/nl-en/what-us-companies-need-to-know-about-sfdr-and-its-implications-on-transatlantic-investment-strategies/#:~:text=U.S.%20companies%20that%20sell%20to,related%20disclosures%20in%20April%202023. 

[49] United Nations Environment Programme Finance Initiative, China Embarks on a Journey of ESG Disclosure, UNITED NATIONS (Jan. 07, 2025), https://www.unepfi.org/industries/banking/china-embarks-on-a-journey-of-esg-disclosure/.