Risk of misleading information disseminated to investors by issuers regarding fossil fuel expansion

The letter argues that high-emitting companies, particularly 'Carbon Majors' like TotalEnergies, provide misleading information to investors regarding their alignment with the Paris Agreement while continuing to expand fossil fuel production. It asserts that climate change poses a systemic financial risk, with potential GDP losses of 50% by 2070-2090, and that current economic models underestimate these damages by ignoring tipping points. The authors highlight a 2025 Paris Judicial Court ruling that TotalEnergies misled consumers and call for ESMA to encourage national authorities to take enforcement action against investor-facing greenwashing to protect market integrity.

• The Paris Judicial Court ruled on 23 October 2025 that TotalEnergies SE misled consumers by claiming to fight climate change while planning to expand fossil fuel production, a decision the company declined to appeal.
• Climate change represents a systemic financial risk that is likely underestimated by current economic models, which often fail to account for Earth system tipping points such as ice sheet collapse or permafrost thaw.
• A small number of 'Carbon Majors' are disproportionately responsible for global emissions; for example, TotalEnergies' 2025 emissions (including Scope 3) represent approximately 1% of annual global GHG emissions.
• TotalEnergies plans to increase hydrocarbon production by approximately 3% per year from 2026 to 2030, with fossil fuels expected to remain between 80% and 90% of its energy production by 2030.
• Institutional investors representing $1.3 trillion in assets have requested the Financial Supervisory Authority of Norway to examine potentially misleading statements by Equinor ASA regarding its alignment with a 1.5°C pathway.
• Despite the risk of market manipulation through misleading climate disclosures, the authors claim there is no effective securities regulatory enforcement in the EU, contrasting this with actions taken by regulators in Australia and the UK.

APA

ClientEarth (2026). Risk of misleading information disseminated to investors by issuers regarding fossil fuel expansion. https://www.clientearth.org/media/4fcjr2le/esma-letter.pdf

Chicago

ClientEarth. Risk of misleading information disseminated to investors by issuers regarding fossil fuel expansion. 2026. https://www.clientearth.org/media/4fcjr2le/esma-letter.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Risk of misleading information disseminated to investors by issuers regarding fossil fuel expansion |date=27 May 2026 |url=https://www.clientearth.org/media/4fcjr2le/esma-letter.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2026risk, author = {{ClientEarth}}, title = {{Risk of misleading information disseminated to investors by issuers regarding fossil fuel expansion}}, publisher = {ClientEarth}, year = {2026}, month = may, url = {https://www.clientearth.org/media/4fcjr2le/esma-letter.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }