A Critical Institutional Analysis of India's Multi-Regulator Sustainable Finance Architecture

Abstract

India has built one of the most active sustainable finance regulatory ecosystems among emerging economies in little more than a decade, moving from a voluntary corporate social responsibility model to a web of mandatory disclosure and green instrument frameworks administered separately by the Securities and Exchange Board of India, the Reserve Bank of India, the Insurance Regulatory and Development Authority of India and the Ministry of Finance. Existing scholarship on this transition largely falls into three categories: descriptive surveys of individual regulatory instruments, ranking exercises that identify barriers such as low investor awareness or high compliance costs, and greenwashing studies that treat misleading disclosure as a corporate governance failure. This paper argues that a more fundamental problem has been under-examined: the absence of a single, coordinated architecture for defining and enforcing sustainability across regulators. Through a doctrinal and chronological analysis of the principal circulars, frameworks and draft instruments issued between 2007 and 2026, this paper maps how the Securities and Exchange Board of India, the Reserve Bank of India and the Ministry of Finance have each generated their own working definitions of sustainability, producing overlapping but non-identical standards, uneven assurance requirements and enforcement gaps that create fertile ground for greenwashing and regulatory arbitrage. Drawing a comparison with the European Union's single Taxonomy Regulation, the paper contends that India's draft Climate Finance Taxonomy represents a genuine inflection point that could either harmonise the fragmented landscape or simply add a fourth competing definition. The paper concludes with a set of coordination-focused recommendations for regulators and policymakers.