Max Tetteroo

Max is an analyst specialised on international and EU sustainability reporting, and policy coherence with other EU sustainable finance policy files. Within these topics, he primarily focusses on implementation challenges, international alignment of disclosure standards, and capacity building needs and opportunities. His geographic focus is primarily on the EU, South East Asia, and India, while his sectoral expertise extends to Agriculture, Farming and Fishing (AFF) and Textiles. Topically, he is interested in sectoral guidance in sustainability reporting, and the potential adverse impacts of regulations on (actors in) the Global South – and how to avoid them.

His goal is to help accelerate the sustainable transition. Towards this end, “we need to make sustainability reporting work in practice, while keeping the ambition of sustainability reporting high. This is absolutely possible, but not a given”.

Other experience includes secondment at EFRAG to support the development of sector-specific standards (AFF), working as a policy analyst for the European Commission, and working for a green tech start up. He holds a Master’s degree in International Relations, with a specialisation in foreign policy analysis, and the (geo)political economy of energy. Max lives in Innsbruck and loves rock climbing.

Latest released papers

Strategy to Leverage Sustainability Reporting: Advancing International Alignment and Capacity Building

April 1, 2025 - This report presents an executive summary of a comprehensive scoping study on the effective implementation of the European Sustainability Reporting Standards (ESRS) . It provides actionable recommendations to enhance ESRS as a tool for economic transformation through international alignment, sectoral approaches, and value chain capacity building beyond compliance. While policy uncertainties may impact ESRS specifics, the core challenges—capacity-building, coherence, and stakeholder engagement—remain pivotal. Discover strategies to leverage ESRS beyond compliance and foster ambitious, globally aligned sustainability reporting that drives transformative change.What's in this publication? This publication sets out key recommendations to unlock the potential of the European Sustainability Reporting Standards for the economic transformation, focused on the role of International Alignment and Capacity Building in the Global South. Towards that end, it sets out a strategy to guide philanthropic efforts along three main pillars: 1. An internationally aligned disclosure system, with high ambition. 2. A sectoral approach to address implementation challenges. 3. Value chain capacity building, beyond compliance. This publication is the executive summary of an extensive scoping study on the effective implementation of the European Sustainability Reporting Standards (ESRS),…

Increasing Coherence Between Disclosure Standards and Frameworks on Biodiversity in G20 Countries | ThinkTwenty (T20) Brasil 2024 – Official Engagement Group of G20

September 19, 2024 - This T20 Policy Brief presents targeted recommendations to increase the coherence between biodiversity frameworks and standards, whilst keeping ambition levels high. The issue is extremely important for the effective transformation of the economic system and business models towards a greener, more inclusive economy and an equitable, nature-positive world. Our recommendations stem from comprehensive overview of the state of disclosure for nature and biodiversity in the G20 countries.The recent adoption of the Kunming-Montreal Global Biodiversity Framework (GBF) marked a significant milestone for halting and reversing biodiversity loss. Its action Target 15 addresses transnational companies and financial institutions, encouraging them to monitor, assess, and disclose biodiversity risks, dependencies, and impacts. As biodiversity disclosure frameworks and standards evolve, harmonization becomes paramount. The users of disclosure information seek to systematically assess and incorporate risks and impacts into their decision-making. To do this, they need reliable and comparable data, but substantial inconsistencies and ambition gaps between disclosure standards and frameworks hinder comprehensive understanding and action on firms’ sustainability performance. Further, firms…

Public Consultation: Materiality Assessment Implementation, and Value Chain Implementation Guidance

February 5, 2024 - This document sets out our joint feedback to the public consultations on EFRAG’s Materiality Assessment Implementation Guidance (MAIG) and Value Chain Implementation Guidance (VCIG).This document sets out our joint feedback to the public consultations on EFRAG’s Materiality Assessment Implementation Guidance (MAIG) and Value Chain Implementation Guidance (VCIG). The document has been drafted collaboratively by Climate & Company and Climate Focus. This work was financed by the Gordon and Betty Moore Foundation and is part of the project "Sustainable Finance Instruments for Sustainable Land Use". [dflip id="3198" ][/dflip]

Public Consultation: Postponement of Deadlines under the Accounting Directive

December 14, 2023 - In this publication we provide feedback to the European Commission's proposal to postpone the ESRS sector-specific standards. We give arguments why we encourage the timely adoption and usage of these standards, why this is possible, and recommendations how to achieve this.In this publication, we provide feedback to the European Commission's proposal to postpone the ESRS sector-specific standards. We give arguments as to why we encourage the timely adoption and usage of these standards, why this is possible, and recommendations on how to achieve this. This document was co-written by our Analysts Max Tetteroo and Raphael Tietmeyer, together with Erin Matson and Georg Hahn from Climate Focus, Florian Haberman from Radboud University, and Frank Schiemann from the University of Bamberg. [dflip id="3195" ][/dflip]

A Framework for Enhancing International Climate Finance Flows | ThinkTwenty (T20) India 2023 – Official Engagement Group of G20

August 1, 2023 - This Policy Brief proposes an institutional arrangement that can build on existing practices, institutions, and domestic acceptance to create a global network of risk reduction instruments for climate finance.CEO David Rusnok from Climate & Company, together with Manish Kumar Shrivastava (Senior Fellow, Earth Science and Climate Change Division, The Energy and Resources Institute (TERI), Heiner Lupke (Senior Researcher, DIW Berlin), Samantha Keen (Researcher, Strengthening National Climate Policy Implementation project), and Karsten Neuhoff (Head of the Climate Policy Department, German Institute for Economic Research (DIW Berlin), prepared this policy brief about a framework for enhancing international climate finance flows. The mobilisation and disbursement of climate finance at the scale and speed required to meet global targets is hindered by high cost of capital. At the root of this high…

Review of the SFDR – biodiversity & value chains

July 11, 2023 - This policy brief reviews the biodiversity, deforestation and value chain aspects of the Disclosure Delegated Regulation of the Sustainable Finance Disclosure Regulation (SFDR), currently being drafted by the European Supervisory Authorities (ESAs).This policy brief reviews the biodiversity, deforestation and value chain aspects of the Disclosure Delegated Regulation of the Sustainable Finance Disclosure Regulation (SFDR), currently being drafted by the European Supervisory Authorities (ESAs). [dflip id="3183" ][/dflip]

Review of the SFDR – GHG reduction targets

- This policy brief highlights our main messages regarding the review of the Disclosure Delegated Regulation of the Sustainable Finance Disclosure Regulation (SFDR), currently being drafted by the European Supervisory Authorities (ESAs). This review focuses on the part “Amendments regarding greenhouse gas (GHG) emissions reduction targets”.This policy brief highlights our main messages regarding the review of the Disclosure Delegated Regulation of the Sustainable Finance Disclosure Regulation (SFDR), currently being drafted by the European Supervisory Authorities (ESAs). This review focuses on the part “Amendments regarding greenhouse gas (GHG) emissions reduction targets”. [dflip id="3180" ][/dflip]

Enabling Local Governance to Mitigate the Climate and Biodiversity Crises | ThinkTwenty (T20) India 2023 – Official Engagement Group of G20

- This policy brief focuses on enabling local governance to mitigate the climate and biodiversity crises.Elisabeth Hoch and Max Tetteroo from Climate & Company, together with Sukanya Das (TERI School of Advanced Studies), Dil Rahut (Asian Development Bank Institute), Gabriel Medina (University of Brasilia) and Benno Pokorny (University of Freiburg), prepared this policy brief on enabling local governance to mitigate the climate and biodiversity crises. The reckless expansion of unsustainable land use, largely induced by supply chains, has led to deforestation, ecosystem conversion, and environmental degradation, which in turn have caused an unprecedented decline in biodiversity and the disruption of ecosystem services. There is growing awareness of the need for global policy, for regulatory, private…

Public Consultation: Feedback on the ESRS Set 1 Delegated Act

July 7, 2023 - This policy brief highlights our main observations and messages regarding the European Commission’s Draft Delegated Act public consultation. This Delegated Act sets out the cross-cutting standards and standards for the disclosure of environmental, social and governance information (ESRS Set 1) of the Corporate Sustainability Reporting Directive (CSRD), which requires actors under its scope (large companies and listed companies) to disclose information on their ESG related risks and opportunities, essential to help investors and others stakeholders evaluate the sustainability performance of companies. What's in it? In this publication, we highlight our main observations and messages regarding the European Commission’s Draft Delegated Act public consultation. This Delegated Act sets out the cross-cutting standards and standards for the disclosure of environmental, social and governance information (ESRS Set 1) of the Corporate Sustainability Reporting Directive (CSRD), which requires actors under its scope (large companies and listed companies) to disclose information on their ESG related risks and opportunities, essential to help investors and other stakeholders evaluate the sustainability performance of companies. Our observations can be summarised in the following messages: Do not further divide the current…

Driving Sustainable Consumption through Policy Innovations in Value Chains | ThinkTwenty (T20) India 2023 – Official Engagement Group of G20

May 29, 2023 - In this policy brief we recommend G20 countries to work together in bridging the intent-action gap to incentivise sustainable consumption practices, shift consumption patterns, and reform consumption and production behaviour. Elisabeth Hoch and Max Tetteroo from Climate & Company, together with Rijit Sengupta, Chief Executive Officer of the Centre for Responsible Business, and Sabarish Elango, Programme Associate at the Council on Energy, Environment and Water (CEEW) prepared this policy brief on incentivising G20 sustainable consumption practices. We recommend that the G20 countries work together in bridging the intent-action gap to shift consumption patterns, and reform consumption and production behaviour by driving the following policy innovations in global value chains. The G20 can incentivise sustainable consumption by: Developing traceable standards to support the credibility of labels and claims. Underlining the need…

Public Consultation: Feedback on the Draft Taxonomy Delegated Act

May 3, 2023 - Read about the key issues with the European Commission's Draft Taxonomy Delegated Act in this publication. The authors focus on biodiversity concerns, including high-impact sectors left out of the draft, insufficiently addressed supply chain impacts, and the need to remove biodiversity offsets. They also raise concerns about specific activities in the transport sector and the weakening of Appendix C.What's in it? In this publication, we provide several messages on what is, and what is not, in the European Commission’s Draft Taxonomy Delegated Act. Building on our continuous involvement in Taxonomy regarding biodiversity (through the Platform on Sustainable Finance and consultations) our first three messages highlight that: high-impact sectors are left out, despite technical screening criteria already being available for adoption. supply chains are still insufficiently addressed and create problems for policy coherence, biodiversity offsets need to be removed. Additionally, we share our concerns regarding the inland passenger/freight water transport and aviation activities, and the weakening of Appendix C.…

Comparative Analysis of Upcoming Disclosure Standards: Key Steps to Raise Ambition (and the case of deforestation)

January 19, 2023 - ANALYSIS: “Comparative Analysis of Upcoming Disclosure Standards: Key Steps to Raise Ambition (and the case of deforestation)” What's in it? An ambitious and internationally-harmonised disclosure landscape is crucial for enabling financial market participants to evaluate and price-in sustainability risks and impacts when making investment decisions. This study structurally analyses three proposals for sustainability and climate-related disclosure standards, published by the European Financial Reporting Advisory Group (EFRAG), the International Sustainability Standards Board (ISSB), and the US Securities and Exchange Commission (SEC) in March and April 2022, along our ‘seven building blocks for effective disclosure standards’. For each building block, we evaluate…

Sustainability due diligence and reporting obligations for financial institutions in EU policies

December 5, 2022 - An overview of the respective obligations for financial institutions across a core set of EU regulatory measures related to sustainability disclosure and due diligence, drawing on the case of deforestation-related risks and impacts.To date, the financial sector plays a significant role in funding investments that contribute to deforestation. Therefore, financial institutions have a crucial role to play in curbing deforestation and associated land-use change, which are key drivers of climate change and biodiversity loss. With this brief, our team at Climate & Company, together with our partners at Germanwatch, aims to provide for a clear understanding of the obligations to expect for financial institutions under each of the relevant recent EU regulatory measures related to sustainability disclosure and due diligence. The case of deforestation This is done by illustrating the respective obligations…

Our comment to the IFRS Sustainability Standards Exposure drafts

November 28, 2022 - These are our comments to the ISSB's sustainability-related disclosure drafts which focus on raising the ambition of the global disclosure baseline as a method of halting deforestation.Following COP26, the IFRS' International Sustainability Standards Board (ISSB) was established to deliver a comprehensive global baseline of sustainability-related disclosure standards. Their exposure drafts (IFRS S1 & IFRS S2) were open for consultation, and our team replied with two comments, one to share our general observations and one to provide in-depth technical feedback. This is particularly important as though we support the initiative and hope to see a quick implementation, we see significant room for improvement. [dflip id="3124" ][/dflip]

Bridging sustainable finance and sustainable land use initiatives to reduce deforestation: An overview of EU and Brazilian legislation

- This technical briefing highlights sustainable finance and sustainable land-use regulations in Brazil and the EU and aims to support regulatory cooperation between the two.Supporting regulatory cooperation on anti-deforestation between Brazil and the European Union Land use change contributes to 23% of global emissions and leads to high biodiversity loss. Deforestation is a major threat to both. Sustainable finance is about “shifting the trillions” from unsustainable towards sustainable economic activities. Therefore, cooperation on anti-deforestation regulation between Brazil and the EU needs to be fostered. To illustrate this, in this policy brief we address the following questions: How can the sustainable finance toolbox support transformation in the land-use sector? What are the EU's plans to halt deforestation caused through its supply chains? And what regulations…

Key actions to safeguard against deforestation in the EU Taxonomy

November 24, 2022 - This paper sets out key actions to better safeguard against deforestation in the EU Taxonomy, building on the key findings of our scrutiny of the Taxo4 report from the EU Platform on Sustainable Finance.This paper sets out key actions to better safeguard against deforestation in the EU Taxonomy, building on the key findings of our scrutiny of the Taxo4 report (Technical screening criteria of the EU Taxonomy's remaining 4 environmental objectives by the EU Platform on Sustainable Finance). Deforestation is an important threat to the EU Taxonomy's environmental objectives, not only as a direct result of certain economic activities (such as agriculture, farming, mining or construction), but also because many sectors and industries are (indirectly) responsible for deforestation through forest-risk commodities in their supply chains. The EU Taxonomy is structured along different economic…

Options & Challenges to Financing the Coal Transition

April 13, 2022 - These insights aid investors and international entities interested in effective and fiscally feasible donor engagements in SPIPA countries.Our research study investigates what kind of international support can be used to bring about a quicker coal phase-out in member countries of the Strategic Partnership for the Implementation of the Paris Agreement (SPIPA). In the current geopolitical context of the war in Ukraine that is set to impact the world’s energy policies for decades to come, this report carves out the challenges, the policy options, the opportunities for a coal exit and the tools that policymakers need to make an effective energy transition happen. Our research insights primarily aid investors and international entities interested in effective and fiscally feasible…