Abstract
This paper presents a comparative analysis of disclosure obligations on sustainable finance in the European Union and the United States. First, it examines the European Commission’s centralized approach to disclosures on sustainable finance. Most of this analysis is devoted to the EU Taxonomy and Sustainable Finance Disclosure Regulation. Second, the paper contrasts this approach with the U.S. Securities and Exchange Commission’s policy, which is largely based on voluntariness and much less comprehensive in its definition of ESG metrics and targets. The paper concludes that for now, the European Commission’s framework meets investors’ demands more decisively and provides more clarity to managers.