How to run a CSR programme that earns trust, not just a press release

Most companies do some good. The problem is how it often looks from outside: a cheque handed over at a photo call, a donation timed for the annual report, a logo on a charity run. Many audiences read these gestures as marketing. Some programmes go further and drift into greenwashing, or its social equivalent, by claiming more impact than they deliver.

This guide shows how to build a corporate social responsibility (CSR) programme that people believe because it has earned it. It is not legal advice.

What audiences and employees now expect

The 2026 Edelman Trust Barometer, based on nearly 34,000 respondents in 28 countries, found that “my employer” is the most trusted institution, at 78% trust among employees, 14 points ahead of business in general at 64%[1]. Yet nearly seven in ten respondents fear that institutional leaders are deliberately misleading the public[1].

People give their own employer some benefit of the doubt, but they are primed to spot spin.

Edelman’s 2025 edition described new guardrails for business. Involvement in societal problems is seen as justified if the business contributed to the problem, could make a major impact on the challenge, and would improve its own performance by acting[2]. A random donation meets none of those tests. A programme tied to what the company knows and does can meet all three.

The rules changed in 2025 and 2026

Generic green claims are now banned

Directive (EU) 2024/825, on empowering consumers for the green transition, amends the EU’s Unfair Commercial Practices Directive. Member states had to adopt national measures by 27 March 2026 and apply them from 27 September 2026[3]. The practices it adds to the EU list of those banned in all circumstances include[3]:

• generic environmental claims, such as “eco-friendly” or “green”, where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim;
• environmental claims about a whole product or business when they concern only one aspect or activity;
• sustainability labels that are not based on a certification scheme or established by public authorities;
• claims, based on offsetting, that a product has a neutral, reduced or positive greenhouse gas impact.

Social claims are covered too

This is where “social washing” comes in. The Commission’s September 2026 Questions and Answers explain that social characteristics, including contributions to social initiatives, are now explicitly among the main characteristics that must not be presented misleadingly, assessed case by case, and that traders should be able to provide evidence for factual claims[4].

The rules apply only to business-to-consumer communications. A mandatory sustainability report is typically outside their scope, but information from it reused in consumer advertising is not[4]. The Commission noted that transposition was still ongoing, so check how your own member state has implemented the rules[4].

The Green Claims Directive is stalled

A separate proposal, the Green Claims Directive, would set minimum rules for substantiating voluntary environmental claims. The Commission adopted it on 22 March 2023, but said on 20 June 2025 that it intended to withdraw it, and the trilogue planned for 23 June 2025 was cancelled[5]. The Commission’s 2026 work programme lists it as pending, and the European Parliament’s Legislative Train, updated on 20 September 2026, marks the file as blocked[5]. Plan around the 2024 directive, not the stalled proposal.

The CSRD now applies to far fewer companies

The Omnibus simplification package has narrowed the Corporate Sustainability Reporting Directive (CSRD). Directive (EU) 2026/470, published on 26 February 2026, limits mandatory sustainability reporting to companies and groups that exceed both €450 million in net turnover and an average of 1,000 employees, and raises the turnover threshold for non-EU companies to €450 million[6].

Member states must transpose these changes by 19 March 2027. They may exempt early reporters that fall below the new thresholds for financial years starting in 2025 and 2026[6].

If your company does not exceed both thresholds, sustainability reporting will be voluntary once national rules are updated. The consumer-law risk attached to anything you say publicly remains.

Choose a cause that fits the business

Start where your expertise gives you the right to act. For banks, insurers, investment firms and payment companies, financial literacy is the natural candidate, and the need is measurable.

The 2023 Flash Eurobarometer on financial literacy, with 26,139 respondents, found that only 18% of respondents across the EU had a high overall financial literacy score[7]. Cyprus shared with Romania the highest proportion of respondents with a low financial knowledge score, at 30%. It also had the lowest share, 19%, who felt confident that investment advice from their bank, insurer or adviser was primarily in their best interest[7].

That last figure is both an opportunity and a warning for financial firms. The European Commission’s financial literacy strategy, adopted on 30 September 2025, links financial literacy to effective budgeting, informed saving and investment choices, retirement planning, responsible debt management and avoiding fraud and scams[8]. A programme built around those needs links your expertise to a recognised public priority.

Design for outcomes, not outputs

Outputs are what you do: sessions run, guides printed, people reached. Outcomes are what changes for the people you serve. Trust is built on outcomes.

The Commission’s strategy calls rigorous evaluation key to judging whether financial literacy initiatives work, including whether they change behaviour, and cites indicators such as savings rates, insurance coverage and supplementary pension participation[8].

In practice:

• Define one problem and one audience. Only 45% of EU respondents answered the Eurobarometer question on compound interest correctly[7]. “Young adults who do not understand compound interest” is a brief you can design for.
• Map the chain. Activity, then knowledge gained, then behaviour changed, then longer-term resilience.
• Set a baseline before launch. The five Eurobarometer knowledge questions, on risk and return, inflation, diversification, compound interest and bond prices, are a tested starting point[7].
• Decide in advance what failure looks like, so results are judged honestly.

Partner with credible, independent organisations

The Commission says private-sector involvement in financial literacy has clear merits, because it mobilises networks, practical expertise and outreach. It also warns that, without a code of conduct, it can lead to real or perceived conflicts of interest, where private entities might promote products or services that serve their own interests[8].

The Commission plans to develop a voluntary European code of conduct from 2027, and says consumer and retail investor associations can serve as trusted, independent advocates that keep education unbiased[8]. Until that code exists, write your own rules:

• the partner researches and writes the material; you approve what carries your name, and it is labelled as supported by you;
• the partner’s own analysis and policy positions stay outside the agreement;
• no product mentions, branded tools or sales follow-up using participant data;
• the funding amount and the independence agreement are published;
• both sides agree in writing what happens if the partner publishes something you dislike.

Tell the story honestly

Disclose sponsorship. EU law already bans using editorial content in the media to promote a product when a trader has paid for it without making that clear[9]. Label sponsored articles, videos and podcasts clearly, at the start and on every repost.

Be specific. The 2024 directive contrasts a generic claim, “climate-friendly packaging”, with a specific one, “100 % of energy used to produce this packaging comes from renewable sources”[3]. Apply the same discipline to social claims. Say how many people completed a course and what changed, rather than promising to “transform financial futures”.

Do not inflate one project into a company identity. The directive bans environmental claims about a whole business when they concern only one activity[3]. The same standard is sensible for social claims.

Report results, including the disappointing ones. Publish outcomes against your baseline, keep the evidence on file and explain what you will change.

Involve employees

Edelman’s 2026 data shows people expect employers to broker trust, with 73% expecting the CEO to lead that effort. Favoured approaches include constructively engaging with employees who criticise the company, at 74%[1]. Deloitte’s 2025 survey found that 89% of Gen Zs and 92% of millennials say a sense of purpose is important to their job satisfaction and well-being[10].

Ways to involve them:

• ask staff to help choose and shape the cause, not just attend the launch;
• offer paid, trained, skills-based volunteering, such as finance teams delivering the partner’s curriculum, with a strict no-selling rule;
• create a channel for internal criticism and respond to it.

How to measure it

Track three levels, and report all of them.

Outputs

Participants, sessions, completion rates and cost per participant. Necessary, but never the headline.

Outcomes

Change in knowledge scores from baseline to follow-up, and changes in behaviour, such as starting to save, checked at three and twelve months. Where possible, compare participants with a similar group that did not take part, and let the partner or an academic run the evaluation.

Trust

Employee participation and survey responses, partner feedback, and whether stakeholders cite your published results rather than your press releases.

Your next steps

1. List every current CSR activity and retire one-offs that fail the fit test.
2. Check your turnover and headcount against the amended CSRD thresholds.
3. Review every public CSR and sustainability claim with your legal adviser against the rules in force since 27 September 2026.
4. Choose one cause tied to your core expertise and define a specific, measurable gap.
5. Sign a written independence agreement with an independent partner, and publish it.
6. Set a baseline and outcome indicators before launch, including what would count as failure.
7. Build an employee volunteering scheme with training, paid time and a no-selling rule.
8. Publish an annual results report that discloses funding and includes what did not work.