ShareAction welcomes ESMA’s proposal to introduce quantitative thresholds for ESG and sustainability related fund names. Quantitative thresholds on their own will not guarantee that funds names are an accurate reflection of their investment strategy and holdings, and further action is needed to curb greenwashing in sustainability disclosures. The recommendations made by ShareAction and other civil society organisations in 2022 remain relevant in that regard. However, thresholds in principle are a welcome step to guide fund managers, supervisors and other stakeholders in identifying and preventing greenwashing. We have provided several suggestions, on how to clarify the guidance and make it more meaningful in its application.