Digital Greenwashing Guide

This updated digital greenwashing guide explores new requirements for accurate sustainability claims about digital products, services, policies, and programs. The guide can also potentially reduce risk and help companies align claims with rapidly changing greenwashing legislation.

Key Takeaways

• Companies make a wide variety of unsubstantiated sustainability claims, including claims related to their digital products and services.
• Changing greenwashing legislation increases potential risks for companies making sustainability claims.
• Emerging web and digital sustainability standards potentially further complicate an already complex greenwashing landscape.
• The rapid rise of artificial intelligence is fueling upticks in greenwashing from both AI companies and the firms that invest in them.
• Advocacy and collective action are needed to put responsible technology regulations in place.

Greenwashing Around the World

Companies regularly make public claims about the sustainability of their products and services. For some, public disclosure is required by law. For others, it might be voluntary or part of independent verification through processes like B Corp certification.

Unfortunately, over half of these statements mislead people or are based on unqualified information. This causes confusion, mistrust, and undermines thriving communities and ecosystems.

Greenwashing has been around since the 1980s. Now, regulations to address the practice are catching up.

Dozens of jurisdictions around the world have enacted anti-greenwashing laws, or are in the process of doing so, including:

• Australia
• Canada
• France
• Great Britain
• The European Union
• United States
• And others…

These laws directly address potential confusion about companies’ green claims. Enforcement can mean steep fines. This will no doubt make greenwashing a more urgent concern moving forward.

The EmpCo Directive

One such law, the European Union’s EmpCo Directive, is now under active enforcement. This legislation empowers consumers to make more educated purchasing choices based on the sustainability claims of companies whose products or services they may wish to purchase. This affects companies that sell to consumers within the European Union, regardless of whether they are based in the EU or not.

The EmpCo Directive includes important enforcement criteria in several key areas:

1. Generic claims: Claims like green, natural, or eco-friendly must be backed by recognized environmental performance.
2. Carbon neutrality: Carbon and greenhouse gas offsets are now banned for products.
3. Labeling: Seals or labels indicating sustainability performance must now be authorized by official certification schemes or public authorities
4. Durability: Sellers must display clear information on product guarantees, repairability, and software update availability.

In other words, to make acceptable sustainability claims, companies must now improve clarity, back up their claims with evidence, and consult public authorities or official certifiers when communicating about sustainability performance.

In light of these evolving regulations, risk increases for companies that make green claims. For example, potential fines under EmpCo could reach up to 4% of annual sales.

Greenwashing [ green-wosh-ing, -waw-shing ]: Communication that misleads people into adopting overly positive beliefs about an organization’s environmental performance, practices, or products.

— Greenwash Action Lab, Lyon and Montgomery, 2015

Greenwashing Intersects with Digital

What’s more, web and digital sustainability intersect with traditional sustainability claims, further complicating an already complex landscape. This adds to confusion and mistrust mentioned above.

So, what might all of this mean for companies that design, build, or manage digital products and services, especially those delivered via the web? How could this potentially impact your product development, digital marketing, or web sustainability efforts? Might your company be at risk of digital greenwashing?

What is Digital Greenwashing?

Digital greenwashing applies the concept of greenwashing specifically to digital products and services an organization creates or manages. In most cases, the laws mentioned above apply here too.

Digital greenwashing includes two important distinctions:

1. Using technology to intentionally spread disinformation about an organization’s sustainability efforts. 
2. Making false or misleading claims about the environmental impacts of an organization’s digital products, services, or programs. 

Sometimes digital greenwashing is done intentionally. Sometimes it’s unintended. Let’s explore how.

From 2022 to 2026, the number of risk incidents linked to greenwashing increased by 112%, while the number of companies linked to greenwashing reached 1,594 in 2026, up 28% from the previous year.

— RepRisk, How the energy transition became greenwashing’s next frontier

How Widespread is Digital Greenwashing?

With companies’ green claims increasingly offering vague or otherwise misleading information, the greenwashing problem is on the rise—hence the need for legislation.

However, digital greenwashing is not as widespread. As an emerging discipline, digital sustainability is just starting to reach the global business community’s collective consciousness. With that said, the explosion of Generative AI tools and hyperscale data centers has also increased awareness of social and environmental issues associated with Big Tech.

Plus, web and digital sustainability practices are easily misunderstood. Given this, we could see more digital greenwashing as web and digital sustainability initiatives gain traction.

For example:

• AI tools become even more ubiquitous in our day-to-day lives, fueling a corresponding rise in awareness of their impact,
• Green IT, web sustainability, eco-design, and related practices become more commonplace,
• Marketers become more attuned to redefining success in their craft to include sustainability principles,
• Legislation around the world shifts toward more transparency, especially for climate disclosures. 

We’re already seeing discrepancies in how organizations talk about these things. The increase in awareness also drives mis/disinformation. As more teams and organizations begin adopting web or digital sustainability practices, we must be vigilant in ensuring the claims they make are accurate, truthful, and evidence-based.

Digital Greenwashing Risks

Given these rapid shifts, organizations might find themselves facing an increasing variety of legal, financial, and reputational risks.

Legal Risks

Sources list a variety of reasons for lawsuits, including: 

1. Disinformation: Making false claims or spreading inaccurate information.
2. Full disclosure: Statements that withhold information or otherwise don’t tell the whole story.
3. Scientific data: Flawed measurement methods or incomplete evidence leads to false claims. 
4. Ratings or labels: Product or service labels offer misleading information about environmental credentials.
5. Net zero: Confusion around carbon offsets and net zero claims translate to organizations making misleading statements about their emissions.

New regulatory guidelines could put any one of these issues front-and-center for organizations across sectors. This is especially true when fines or penalties are associated with legislative non-compliance. We’re likely to see an explosion of lawsuits moving forward as more regulatory guidance goes into effect.

Because sustainability isn’t as deeply entrenched in tech as it might be in other industries, this should concern organizations that create or manage digital products and services.

Intersectional Risks

Moreover, companies making claims related to web or digital sustainability may try to simplify complicated or otherwise esoteric concepts in order to broaden audience understanding. In doing so, they can quickly run into several sustainability pitfalls:

• Complexity: Organizations may not acknowledge in their communications that digital sustainability includes many overlapping, interdependent disciplines from IT and engineering, UX or product design, marketing and communications, ESG and sustainability, and others.
• Third parties: Plus, most digital products and services include a vast number of third-party services in their digital supply chains. From plugins to ad trackers, AI tools, bots, analytics platforms, CRM systems, content delivery networks (CDNs), web hosts, data centers, and many others, these adjacent systems often go unaccounted for in impact reporting.
• Scope 3 emissions: In turn, this oversight curtails emissions reporting, especially Scope 3 categories for Purchased Goods and Services (upstream category one) and Use of Products Sold (downstream category eleven).
• Human factors: Finally, social issues like planned obsolescence, family living wage, accessibility, and many others may take a back seat to energy and emissions, exacerbating problems associated with carbon tunnel vision.

When communications teams don’t clearly understand how to tell compelling, technology-related sustainability stories that are backed up with clear evidence, actions, and facts, organizations are at risk. 

Other Related Risks

However, tech, communications, and legal risks are not the only concerns. Others include:

• Trust: Loss of trust and damage to reputation and/or brand image
• Customers: Attrition and associated revenue loss stemming from mistrust
• Partners: Damage to client and partner relationships
• Advertising: Loss of advertising or other revenue 
• Investigations: Regulators or watchdog groups put you on their radar
• Culture: Increased employee turnover and destruction of company culture
• Costs: Higher insurance, supplier, or other costs associated with changing systems
• Investment: Difficulty attracting investors or financial support

Given all this, the likelihood of an organization engaging in digital greenwashing—intentionally or not—is high. Once again, the message is clear: make truthful statements about sustainability efforts, backed up with data and scientific evidence, to improve your organization and avoid fines or lawsuits. This includes marketing claims related to digital products and services.

Executives should be transparent about their sustainability successes and failures rather than trying to massage the perceptions of the market. Eventually regulators, such as accounting bodies, may make ESG disclosures compulsory, finally closing down the greenhushing option.

— Planet Tracker, Greenhushing — Sophisticated Greenwashing?

Response to a Shifting Landscape

Similarly, as greenwashing quickly evolves, so too do the practices associated with it. The examples below provide context for how the changing legislative landscape is, in turn, shifting company practices.

1. Greenhushing

First, the backlash to company greenwashing has led to a rise in greenhushing, where companies downplay, strategically select, refuse to report, or even talk about their sustainability efforts.

Greenhushing is problematic for several reasons:

• Disinformation: Greenhushing can lead consumers to believe that a company is more sustainable than it actually is.
• Urgency: In the middle of this climate emergency, we need organizations of all sizes, in all industries and sectors, to step up and share knowledge about their sustainability efforts, continuous improvement journeys, processes, and so on. 
• Valuation: Similarly, companies use vague or downplayed sustainability claims to attract a green valuation from investors, regardless of whether or not they actually walk the walk.

With the rise of authoritarianism and pushback on ESG, DEI, and other practices crucial to a more equitable and regenerative future, we need more companies talking about their sustainability journeys, not less.

Greenhindering is the glorification and normalization of unsustainable behaviors or practices, whether intentional or unintentional, by agents of socialization, which make those behaviors and practices much more difficult to eliminate.

— Raz Godelnik, Why Greenhindering is the New Greenwashing

2. Greenhindering

Promoting unsustainable behaviors makes those behaviors much more challenging to eliminate. In fact, normalizing problematic practices through greenhindering bakes them into cultural norms, undercutting counteraction efforts.

Regardless of whether these efforts are intentional or not, they actively block sustainability progress. Legislation can help companies change corporate behavior. However, cultural norms offer bigger impediments to meaningful change.

3. Greenshouting

Conversely, greenshouting offers meaningful alternatives to greenhindering or greenhushing. It “equips teams to communicate sustainability progress with confidence, credibility, and cultural impact,” according to the Greenshouting Guide, created by B Lab and Creatives for Climate.

Applying greenshouting to web or digital sustainability efforts is important precisely because these practices are so rare, especially in traditional businesses. Greenshouting helps more people understand web or digital sustainability and apply these practices to their own work.

Plus, telling authentic stories about the actions you take builds trust and integrity and eases tension among organizational stakeholders. It also helps affected parties across your business ecosystem better realize the multitude of benefits associated with investing in sustainability.

Digital Greenwashing Examples

We have identified the examples below as evidence of digital greenwashing. However, our hope is for companies that have engaged in these practices, unwittingly or not, to consider reexamining them.

Mightybytes is always up for engaging in constructive, open dialogue on any topic. To that end, we will update, edit, or even remove examples listed below if a company can provide clear, scientific evidence to back their claims.

1. Green Website Badges

Proclaiming your website is more green than it actually is spreads misinformation in an emerging discipline that should be grounded in truth and transparency. 

What it is

Organizations create ‘green’ web badges for customers to use on their websites. These tags are intended to showcase a website’s green credentials based on hosting choices, purchased carbon offsets, and other schemes. The badges are often accompanied by inbound links to a provider’s website, which is good for SEO and sheds light on potential incentives.

Why it’s greenwashing

Legislation is consistently moving toward independent verification of claims. In this vein, companies that create their own green claim badges are considered greenwashing, especially if those claims are not verified or based on scientific evidence. Plus, these badges are sometimes based on carbon offset purchases, which are, in the case of the EmpCo Directive, no longer permissible.

With that said, Green web hosting is an important step toward creating an internet that’s entirely powered by renewable energy. However, it is only one piece of a much larger puzzle. Yes, it is admirable to commit to powering your hosting with renewable energy. However, the web has many moving parts, each of which present significant environmental and emissions challenges.

Claiming that a website is ‘300% green’ because of a hosting choice or carbon offsets purchase is misleading.  

What to consider instead

To improve education and increase transparency, try the following:

• Reduce first: Focus on reducing potential environmental impacts associated with digital products and services. This could mean improving performance and efficiency, moving to new third-party providers, or redesigning products or services to use less resources.
• Share the story: Next, share details about your efforts. Who are you partnering with? Why is that important? How do you make progress? And so on. Include this information in content such as partner briefs, marketing posts, and annual impact reports. Back up claims with clear data and statistics. Don’t tout your green credentials, but rather educate and inform. 
• Continuous improvement: Finally, commit to continuously improving performance and communicating the progress you make over time. Show month-over-month or year-over-year performance whenever possible.

Most importantly, be transparent about how far you still have to go. We’re all learning in real-time when it comes to digital sustainability. Being clear about this fact encourages trust. 

2. Digital Emissions ‘Calculations’

Dozens of online website carbon tools exist. Many of them offer free digital carbon estimates. Unfortunately, these estimates sometimes promote misleading claims.  

What it is

Companies use data from online greenhouse gas (GHG) estimation tools to make unclear claims about emissions from their digital products and services. Sometimes this is done using website badges, similar to the example above.

Other times, the misleading data appears in impact reports, social media posts, press releases, online articles, and so on. This is problematic.

Why it’s greenwashing

Similar to example #1, the figures offered by most ‘carbon calculators’ only represent broad stroke estimates for a complex and always-changing technology system at a single point in time. Worse, some companies behind these tools use them as excuses to drive carbon offset purchases, which isn’t the most viable or recommended approach to digital sustainability. 

These tools are great for jumpstarting conversations within organizations that wouldn’t otherwise prioritize digital sustainability. However, the main problem lies in translating the information they provide to organizational marketing campaigns and communications strategies. When companies don’t clearly acknowledge data gaps, their claims are misleading. The language we use to describe digital GHG models matters. 

What to do instead

IAB Europe’s Sustainability Standards Committee offers clear language recommendations on how to talk about your digital emissions evaluation initiatives. For example:

• Use evaluation or assessment over measurement.
• Consider emissions estimates vs. emissions calculations.
• To represent the full spectrum of greenhouse gases, opt for GHG assessment or GHG evaluation over carbon-specific language. 
• Similarly, use GHG Estimator or GHG Models over carbon calculators.

We always strive to improve how our own web sustainability tool, Ecograder, and the Sustainable Web Design site present this information. We encourage others to do the same. 

Beyond using IAB’s language guidelines, also consider investing in a digital life cycle assessment to better understand the full environmental impact of digital products and services you create and use.

Free online estimation tools don’t offer a complete picture of your website’s environmental impact. Plus, the issue is only further complicated by emerging Generative AI tools that offer the same service.

3. Websites with ‘Low Carbon Mode’

Low carbon mode websites can potentially undermine sustainability efforts rather than support them.

What it is

Websites feature a low carbon mode switch, similar to dark mode, that can be used to turn on lower impact sustainability features. However, these switches are sometimes designed and built in ways that negate potential sustainability benefits. 

The most high profile example of this was the COP28 website.

Why it’s greenwashing

In the case of COP28, the full-featured site, with all its bells and whistles, loads before users are offered an option to switch to a more lightweight low carbon mode. This is wasteful.

Plus, as a U.N.-sponsored global conference, COP websites receive significant traffic—between 450,000 to 500,000 monthly visits during off months. This increases exponentially as the conference draws near.

While this feature might have been well-intentioned, implementation was shortsighted. For a complete breakdown of all the sustainability problems with the COP28 website, please read CSS in Real Life’s excellent Greenwashing and the COP28 Website or Fershad Irani’s COP28 UAE: A Low Carbon Website Review. 

What to do instead

Simply put, web sustainability offers viable design challenges. Utilizing practices established by W3C’s Web Sustainability Guidelines, product teams have robust tools at their disposal to meet this challenge without compromising quality.

The promises of planet-saving tech remain hollow, while AI data centres breathe life into coal and gas every day. These claims of climate benefit are unjustified and overhyped, and could cover up irreversible damage being done to communities and society.

— Ketan Joshi, Big Tech Accused of AI ‘Greenwashing’ Resilience

4. Green Data Center Claims

The explosive rise of AI across sectors has catapulted the energy, emissions, and water impacts of hyperscale data centers into mainstream conversations. To combat this, hyperscalers use greenwashing tactics that claim to minimize their impacts.

What it is

Data center companies make a variety of green claims to draw attention away from the effects they have on communities and ecosystems. Food & Water Watch identified seven data center greenwashing claims to watch out for:

1. Renewable Energy: Data centers utilize renewable energy claims while still relying on fossil fuels and pretending broader impacts of data centers don’t exist.
2. Wastewater: Data centers use huge amounts of water for electricity and cooling, making wastewater recycling claims that don’t live up to the promise.
3. Closed loop systems: Data center closed loop cooling system claims that supposedly consume zero water are just clever advertising since these systems lose water volume, consume more energy, and introduce toxic chemicals.
4. BYOP: ‘Bring Your Own Power’ schemes connect data centers directly to power sources in numerous ways. However, these schemes often don’t advance affordable and readily accessible renewable energy.
5. Carbon Capture & Storage: An unproven technology that has failed repeatedly, carbon capture is often paired with natural gas to make false claims or dangle empty promises of low emissions facilities.
6. Biogas: Expanding factory farm gas to fuel data centers increases pollution and emissions, including methane, and expands fossil fuel infrastructure. Using labels like “biogas” or “renewable natural gas” greenwash a dirty energy source.
7. Generative AI: Finally, claims that Generative AI will help us solve climate change are greatly overstated. Real-world research or use cases show ‘traditional’ AI as being more useful and not agents, chatbots, or media generators driving current explosive growth.

Why it’s greenwashing

With the rapid pace at which they are expanding, the social and environmental impacts of hyperscale data centers is an urgent concern.

What to consider instead

Unfortunately, responsible technologists have precious few alternatives to choose from. However, as concern grows, so too do resources related to those concerns. Here are a few:

• Playbook: If a data center is scheduled to be built in your community, the Alliance for the Great Lakes’ Data Center Playbook offers helpful tactics and resources to help communities understand potential impacts and ask the right questions at the right time.
• Providers: There currently aren’t many greener AI providers, but companies like GreenPT and others embrace more sustainable and privacy-focused AI in the tools they offer.

Ultimately, multifaceted transparency and coordinated policy responses are essential to realize genuine sustainability in disruptive, high-impact technologies.

— Seeing through the haze: greenwashing and the cost of capital in technology firms, Environment, Development, and Sustainability (gated content)

5. Tech Investment Greenwashing

Firms financing the AI expansion ride Big Tech’s greenwashing coattails.

What it is

With trillions in investments, AI represents one of the largest capital deployments in human history. Firms making these investments claim energy efficient models and highlight how we can potentially use AI to solve the climate crisis.

This messaging ranges from presentation talking points to slick sustainability reports, using questionable green features to distract from broader problematic investment portfolio issues.

Why it’s greenwashing

By selecting what they choose to highlight, investor narratives pull a bait and switch. First, they conflate older, more traditional machine learning models with resource-intensive generative AI and chatbots when verifiable proof that links generative AI tools to reduced energy or emissions is lacking. 

Plus, with this much capital investment in technology deployments that feature unprecedented social and environmental impacts, spotlighting minor sustainability accomplishments distracts from bigger issues at play.

What to do instead

We need a systems-level economic overhaul to combat shareholder primacy. However, until that happens, follow the money, then move your money.

Things you can do include:

• Use a resource like the Impact Evaluation Lab to understand impact claims by current investment partners and research better options.
• Transfer banking to a B Corp bank like Climate First Bank or other members of the Global Alliance for Banking on Values. Not sure if your bank funds climate chaos? Check out Bank.Green to find out.
• Support advocacy and collective action efforts like those spearheaded by B Lab, the organization that certifies B Corps.

Plus, as digital sustainability continues to grow, more projects will require funding. Where the money comes from for these projects matters.

Greenwashing confuses the public, minimises the severity of the global climate crisis and so ultimately pushes us closer to climate catastrophe.

— Harriet Lamb in Number of adverts banned for ‘greenwashing’ triples in a year, The Independent

Seven Actions to Avoid Digital Greenwashing

To reduce digital greenwashing risks, here are seven action items to consider.

1. Understand Your Why

First, whether you’re looking at digital emissions or broader web or digital sustainability efforts, ask why is it important to make a claim?

Common reasons include:

• Reporting compliance
• Creating an actionable roadmap
• Staying competitive
• Attracting investors
• Reducing risk
• Satisfying requests from leadership
• Pressure from internal teams, customers, or other stakeholders

The rationale matters. Spend time figuring it out.

2. Assess Your Risk

Next, before making any digital sustainability claims, assess the risk of doing so. What unintended circumstances might come from your actions?

Analysis that specifically targets web or digital sustainability will help you understand potential risk factors associated with claims you make about your efforts. For example, no website is actually ‘sustainable’.

3. Understand Stakeholder Needs

Explore the systems in which you do this work through activities like stakeholder mapping to inform business decisions and better understand stakeholder needs. Collaborate and employ participatory design practices whenever possible.

4. Use Existing Sustainability Frameworks

Align sustainability storytelling, advocacy, and reporting efforts with existing frameworks or known standards whenever possible to reduce potential pitfalls. A Sustainability Management System can help with this.

5. Be as Specific as Possible

Sweat the details. Specificity matters, especially if you want to avoid lawsuits or fines. You don’t have to know, or include, everything, just the right things. You should clearly understand where gaps in your knowledge might lie.

6. Make Data-driven Decisions

Define—and implement—a sustainable data strategy to back up your claims with data and clear evidence. While overall this can be a lengthy endeavor, start small with what you can control. The handy guide below can help you put a plan in place.

7. Progress Over Perfection

Finally, own your mistakes and improve out in the open. Share what you learn along the way and ground all your work in honesty and transparency. 

Good data governance and broader digital governance practices go a long way toward operationalizing digital sustainability within your organization. However, this requires buy-in from leadership and an educated marketing and communications team tasked with training both internal and external stakeholders on the issues. 

Technology can play a significant role in reducing greenwashing by providing tools and resources that promote transparency, accountability, and accurate measurement of environmental impact.

— Unaise Urfi, The Role of Technology in Greenwashing

Digital Greenwashing: Final Thoughts

Technology can help us design and build a more equitable and regenerative future. However, when we use it to intentionally misinform people or, worse, create technology that itself has destructive traits which undermine social and environmental progress, we sabotage our chances to successfully achieve this future.

What’s more, when leaders don’t educate themselves or take due diligence steps to ensure their sustainability claims are accurate and truthful, they put their organizations at legal and financial risk.

Finally, this is not legal advice. Should you require legal assistance, please consult a lawyer. 🙂

Below are five common questions related to greenwashing in digital products and services.