Washing as a Strategic Risk: What the C-Suite Should Demand

"Communicating progress that cannot be demonstrated is a strategic risk, with consequences that extend beyond reputation."

Greenwashing-washing-sostenaibility

In executive committees, the same tension usually appears: “We know sustainability matters, but it can’t distract us from the business.” The reality is that today sustainability is business, because it has become a factor that drives trust, social license, access to capital, customer preference, talent attraction, and increasingly, regulatory compliance.

The European Commission found that 53% of environmental claims in the EU market offer vague, misleading, or unfounded information, and that 40% have no evidence to support them. The gap between what is said and what can be proven is structural, and organizations that ignore it are exposed.

Many organizations fail due to a more basic risk than lack of strategy or material-issue-focused initiatives: falling into some form of “washing.” Communicating or implying progress that cannot be demonstrated, or that is disconnected from operational decisions. That risk is strategic, and exceeds the category of “reputation” in the abstract.

Why did washing become a C‑suite risk?

Because the standard of evidence changed. Today, simply saying “we are responsible” or “we are committed” is enough for the next question to arrive immediately. The question that investors, regulators, media, and employees ask is more specific:

What the C‑suite is already being asked

  • What changed in the business model?
  • What metrics support the progress, with what method and what scope?
  • What is under control and what is not yet?

When the answer is neither clear nor verifiable, others complete the story. And when that happens, the credibility of leadership is compromised, and with it much more than a campaign.

Two common forms of washing (and why they occur)

In practice, washing often appears as a problem of asymmetric information and signals: “appearing” sustainable is rewarded before “being” sustainable. In management terms, what often lies behind is decoupling: the company says one thing, but operational decisions, incentives, and controls continue to function as before.

And when that decoupling becomes “normal,” a very human temptation enters organizations: the sin of “fibbing.” Most of the time it involves rounding, softening, omitting limits, or presenting as a system what is still a pilot. Rarely does it involve lying “big.”

To ground this, two typical forms (with examples connected to what people do day to day):

Greenwashing (environmental)
The “green” narrative decouples from operations: marketing and sales use broad phrases like “eco,” “green,” or “carbon neutral,” but no one can explain (quickly and with evidence) what is included, what is excluded, and how it was calculated. It also happens when a campaign is built around a minor attribute (packaging, a specific initiative) while purchasing, logistics, or production do not change the material drivers of impact.
ESG / Impact washing (results vs. narrative)
The “impact” narrative decouples from traceability and governance: “activities” are confused with “results” (“we did trainings,” “we launched a program”), but there are no goals, indicators, or clear owners to demonstrate changes. Externally, inspiring stories are told; internally, no one has a simple and consistent answer to: “What changed in emissions, safety, supply chain, compliance, or human rights?”

In both cases, the problem lies in the decoupling between what is said and what is done. “Fibbing” appears as a shortcut to close that gap in the narrative… until someone asks for evidence.

The cost of falling into washing

For a C‑suite, the cost goes beyond an uncomfortable headline. It translates into tangible impacts:

⚖️ Legal and regulatory
Claims that can be interpreted as misleading. The EU CSRD contemplates fines of up to the 5% of annual global revenue for serious non-compliance. The FTC in the US imposes up to USD 50,120 per violation.
📉 Financial
Loss of access to investors or higher cost of capital when ESG information lacks reliability. Funds that apply ESG criteria no longer accept unsupported claims.
🤝 Commercial
Boycotts, loss of contracts, demands from corporate clients who ask for evidence. Supply chains replicate scrutiny toward their suppliers.
🏠 Internal
Trust fractures when people “don’t recognize” the company that communicates outward. The effect filters to Glassdoor, LinkedIn, and informal conversations.

And the numbers support the urgency. The European Commission found that 75% of products in the European market carry an implicit or explicit environmental claim. Of those, more than half offer vague or unfounded information. The gap between narrative and evidence is the norm, and regulators are already closing it.

53%
of environmental claims in the EU offer vague, misleading, or unfounded information.
Source: European Commission, study on green claims in the EU market.
40%
of claims have no evidence to support them.
Source: European Commission.
75%
of products in the EU market carry an environmental claim.
Source: European Commission / Sweep, 2025.

The regulatory net is closing

Regulation is no longer voluntary. The CSRD (Corporate Sustainability Reporting Directive) of the European Union obliges thousands of companies to report with auditable standards, and contemplates fines of up to 5% of annual global revenue for serious non-compliance. From September 2026, the ECGT (Empowering Consumers for the Green Transition) directive bans self-demonstrated sustainability labels and generic environmental claims. In the United States, the FTC can impose fines of up to USD 50,120 per misleading claim.

For organizations operating in Latin America, the effect arrives through two channels: local regulators adopting international standards (SASB, IFRS S1/S2) and European or North American corporate clients demanding evidence of sustainability as a condition for hiring.

How to avoid washing without falling into silence?

Avoiding washing means speaking better: with precision, clear limits, and verifiable data.

Executive checklist: five tests before communicating

01. Materiality first: communicate what is material to the business and its stakeholders, not what is most attractive for a piece.
02. Definitions and scope: if a goal is mentioned (“net zero”), explain what is included, what is excluded, and by when.
03. Comparable metrics: use recognized frameworks when applicable (SASB/IFRS for industry) and be consistent year over year.
04. Visible governance: make clear who makes decisions, who approves the data, and what incentives exist.
05. Balance: report progress and gaps. Transparency about what remains unresolved is an asset.

The message for leadership

Sustainability is protected with management discipline: clear priorities, solid metrics, accountability, and responsible communication.

The market forgives imperfection. The perception that reality was “dressed up” has no return.

Paulina Rodríguez
Komunika Latam

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