European regulators are taking greater steps to clamp down on companies’ misleading environmental, social, and governance (ESG) claims, but experience shows different countries have differing priorities about tackling dishonest marketing.

While the focus of many countries is to target the biggest offenders capable of harm, there appears to be a split about which industries are most at fault and which regulators should take the lead.

Several European Union countries—including Denmark, France, Germany, and the Netherlands—and the United Kingdom have identified the financial services sector as being one of the biggest culprits, particularly regarding trying to entice pension funds to invest in supposedly green funds. As a result, financial regulators in these countries have been vocal in their desire to see the bloc pass EU-wide legislation to prevent greenwashing.