ESG Communication Without Overclaiming

ESG Communication Without Overclaiming: Why Language is Emerging as a Core Capability in 2025

Environmental, Social and Governance (ESG) performance has become a routine expectation in corporate communication across the UK and EU. For organisations selling into B2B ecosystems—particularly those in early or transitional stages of ESG maturity—the challenge is no longer whether to speak about sustainability, but how to do so responsibly. While regulatory frameworks such as the Corporate Sustainability Reporting Directive (CSRD), the EU Taxonomy and the Green Claims Directive influence hard requirements for large firms, they also create secondary pressure on SMEs and service providers through procurement, buyer expectations and investor due diligence. As this pressure increases, language itself is becoming a new locus of risk: claims made without evidence, undefined terms, and casual references to frameworks can be interpreted as misleading or, in some cases, greenwashing.

This paper argues that ESG communication is now a capability—not a soft skill, not a marketing task, and not a compliance function. It is a structural requirement for participating in ESG-mature markets. The capability centres on clarity: alignment before compliance, transparency before targets, and risk-aware messaging instead of impact-based claims.

1. The Structural Drivers Behind Communication Risk

Three forces are converging to make ESG communication failure more costly in 2025:

• Regulatory spillover: Even if a company is not directly subject to CSRD, GRI or SECR reporting, their clients or investors may be—meaning expectations travel downstream. A SaaS provider selling to a regulated manufacturer may face ESG questionnaires, impact attributions or claims verification requests simply because they are part of the buyer’s audit trail.

• Procurement as enforcement: In the absence of universal regulatory coverage, procurement teams increasingly act as informal enforcement bodies. Terms like alignment, impact and sustainability contribution are interpreted through due diligence processes, which means communication becomes a de facto compliance interface.

• Litigation and reputational asymmetry: Greenwashing cases tend to produce asymmetric impact. A small claim—“reduces emissions” or “compliant with ESG standards”—can result in outsized reputational damage if contested. Importantly, the burden of proof typically falls on the claimant, not on the challenger.

The result is a market where silence is no longer viable, but speaking carelessly is riskier than ever.

2. Why Misalignment Happens

Most overclaiming is not malicious. It tends to emerge from one of four structural gaps:

These gaps reflect an underlying tension: most companies are in progress, but language often implies completion.

3. The Role of Language in ESG Maturity

It is misleading to conceptualise ESG maturity as binary (compliant vs non-compliant). Instead, research suggests that maturity is experienced as a set of overlapping gradients:

• Awareness → Literacy

• Literacy → Boundary setting

• Boundaries → Evidence gathering

• Evidence → Claims

• Claims → Assurance

Communication should reflect the stage the organisation is actually in. Saying “we are not there yet” is, in many cases, the most credible statement available.

This is particularly relevant for SMEs. Unlike large corporates with sustainability officers and audit functions, early-stage teams need language infrastructure before data infrastructure. In other words, before organisations know what they can claim, they must know what they cannot.

4. Risk-Aware Communication Principles

A growing body of ESG communication practice converges on five principles that reduce risk while maintaining credibility:

1. Clarity before claims
   Avoid benefit-driven claims until proof exists; foreground process and intent.

2. Boundaries before benefits
   Define scope. State what is not offered. (“Not a carbon accounting tool”)

3. Evidence before impact
   Evidence is a prerequisite to impact attribution, not an optional enhancement.

4. Alignment before compliance
   Alignment describes direction; compliance describes status. They are not synonyms.

5. Progress before perfection
   Maturity is iterative; language should reflect development, not completion.

These principles do not weaken ESG messaging. They make it usable.

5. Safer Language Constructions

The following constructions demonstrate how language can support ESG maturity without implying compliance or impact:

• Conditional language: may support, can contribute to, depends on context

• Scope descriptors: not a substitute for compliance, not a measurement tool

• Temporal qualifiers: currently exploring, developing pathways

• Alignment clarifiers: reference terminology, avoid implying certification

Used consistently, these constructions create a communication environment where expectations are managed, not inflated.

7. Implications for UK-based SMEs in 2025

For UK-based SMEs—particularly those operating under the Graduate Route or early-stage visa categories—the ESG labour market is uneven. Many firms cannot support an in-house sustainability function, but face ESG-conditioned market access. As a result, the emerging service requirement is not for full compliance or certification, but for translation, boundary-setting and clarity.

This is where independent research & communication studios operate: between marketing and compliance, creating the connective tissue that allows organisations to speak responsibly while they build capacity.

Conclusion

The ESG landscape in 2025 is characterised by pressure, asymmetry and uncertainty. In this environment, language becomes a strategic tool: capable of unlocking or obstructing commercial pathways. Companies that invest in communication clarity—before claims, before targets, and even before measurement—position themselves for credible participation in sustainability-structured markets.

ESG communication is now an operational capability.
Not reports — deliverables you can actually use.