Faculty of law blogs / UNIVERSITY OF OXFORD

Mapping Sustainable Finance Taxonomies: A Global Empirical Perspective

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3 Minutes

Author(s):

Dirk A Zetzsche
Professor of Law and ADA Chair in Financial Law (Inclusive Finance) at the Faculty of Law, Economics and Finance, University of Luxembourg
Madeleine Mahoux-Pflücke
Research and Development Specialist at the Faculty of Law, Economics and Finance, University of Luxembourg

Sustainable finance has moved from voluntary market practice to a core element of financial regulation. As governments increasingly rely on private capital to finance the transition to a low-carbon and socially inclusive economy, a fundamental question has emerged: what counts as ‘sustainable’?

Outside of the US, sustainable finance taxonomies have become the dominant regulatory response. These frameworks classify economic activities according to environmental and, increasingly, social sustainability criteria. While the EU Taxonomy initially set the pace, it is no longer the exclusive actor in the field. Taxonomies are now being adopted or developed on a global scale. It suggests that taxonomies are no longer experimental policy tools. Instead, they are rapidly becoming a global regulatory infrastructure that shapes financial markets, disclosure practices, and capital allocation.

Our paperrecently presented at the Empirical Legal Studies Discussion Group at the University of Oxford, presents the first global empirical assessment of sustainable finance taxonomies. It is based on a hand-collected dataset of 50 adoptedand developing taxonomies worldwide, as of December 2025. Using qualitative content analysis, the study compares how jurisdictions operationalise sustainability objectives through taxonomy design, focusing on objectives, sectoral scope, methodological approaches, governance models, and legal embedding.

The analysis reveals a pattern of both convergence and divergence. On the one hand, taxonomies increasingly converge around core design features. Across jurisdictions, frameworks tend to define clear sustainability objectives, adopt activity-based classifications, and rely on technically rigorous criteria intended to enhance credibility and comparability. These shared elements reflect a common regulatory ambition to create usable and reliable sustainability benchmarks for financial markets.

On the other hand, significant differences persist in governance arrangements and legal integration. Some taxonomies are closely embedded in binding regulatory frameworks, such as disclosure obligations or supervisory expectations, while others function primarily as voluntary reference tools. The study identifies distinct income-level patterns explaining these divergences: high-income jurisdictions tend to prioritise environmental objectives and climate-related granularity, whereas middle- and lower-income economies more frequently integrate social considerations alongside ecological goals.

These deviations reflect broader tensions between regulatory harmonisation and openness to innovation in sustainable finance. While convergence supports comparability and cross-border capital flows, flexibility allows taxonomies to accommodate diverse economic structures and policy priorities.

By situating these empirical findings within the literature on financial regulation and sustainability transitions, the paper argues that sustainable finance taxonomies function not only as classificatory tools but also as instruments of norm creation and policy coordination. As taxonomies become embedded in disclosure regimes, investment frameworks, and supervisory practices, their design choices increasingly shape market expectations and regulatory trajectories.

Understanding how taxonomies are designed and governed across jurisdictions is therefore essential. As sustainable finance regulation continues to evolve among regulatory fragmentation and shifting political priorities, empirical insights into taxonomy design can help inform debates about the future role of these frameworks in global financial governance. 

A further insight emerging from the empirical mapping concerns the stage of development at which most sustainable finance taxonomies currently stand. While taxonomies are often discussed as finished regulatory products, the data suggest that the global landscape is still characterised by experimentation, sequencing, and gradual expansion. In practice, many taxonomies start with a relatively narrow focus or adaptable design, allowing policymakers to gain experience before expanding their scope or level of detail. From this perspective, taxonomies are better understood not as fixed classification systems, but as frameworks that may evolve in response to regulatory experience and changing policy priorities.

The findings also indicate that design choices are strongly shaped by institutional capacity and economic structure. Jurisdictions with advanced data infrastructures and supervisory resources tend to opt for granular, technically dense frameworks, whereas others prioritise usability, transition finance, and broader social objectives. Importantly, this does not reflect weaker regulatory ambition, but rather different pathways toward sustainability that align with domestic development priorities. The coexistence of these approaches challenges the assumption that convergence necessarily requires uniformity.

Viewed together, the global spread of taxonomies points to a phase of consolidation rather than completion. As more jurisdictions move from development to implementation, questions of revision, expansion, and recalibration will become more prominent than their initial design. Therefore, the empirical evidence suggests that the future of sustainable finance taxonomies lies not in replicating a single model, but in managing diversity within an increasingly interconnected regulatory landscape.

Overall, the paper seeks to explain how sustainable finance taxonomies are evolving from technical classification tools into core elements of financial regulatory architecture, by providing the first global empirical mapping of taxonomy design, governance, and legal embedding. It aims to inform ongoing debates about convergence, interoperability, and the future role of taxonomies in sustainable finance regulation. 

The full paper is available here.

Dirk Andreas Zetzsche is the Head of the Department of Law and Full Professor in Financial Law, and Madeleine Mahoux-Pflücke is a Research and Development Specialist at the Faculty of Law, Economics and Finance, University of Luxembourg.