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Maybe you’ve seen a few headlines or received a legal memo without paying much attention. Now is the time to take this seriously. Since June 2024, the Competition Act has been strengthened to address greenwashing directly*. And starting June 20, 2025, any company making an environmental claim without solid proof can be taken to court by any private individual. The risks? Fines of up to $15 million or 3% of global revenue, orders to withdraw claims, or even the publication of corrective notices.

In short, greenwashing is no longer just a reputational issue—it is now a legal and financial risk.

So, what exactly does Bill C-59 require, and more importantly: how can you avoid missteps?

What Bill C-59 Changes in Practice

Since the bill was adopted in June 2024, businesses and organizations, no matter their size, must back up their environmental claims with solid evidence.

What the law requires:

• Statements must be truthful, precise, and not misleading;
• No generalizations or exaggerations (the overall impression given by the claim must be considered);
• Proof must be available before publication;
• And, for claims about the company’s commitments, sufficient supporting evidence obtained using internationally recognized methods.

Note: The law does not specify what constitutes “internationally recognized methods.” The lack of clarity remains… so caution is essential. In plain language: vague formulas like “good for the planet,” “clean technology,” or “carbon neutral” are over, unless you have solid supporting data.

Not Retroactive, But Watch Your History

The law is not retroactive. In other words, a statement published before June 20, 2024, cannot be prosecuted under the new provisions. However, if that statement is still online or in your public materials and continues to influence the public, it could still be reviewed under existing rules on misleading advertising.

June 2025: Complaints Open to the Public

The big change is that as of June 2025, any private party or individual can file a complaint with the Competition Tribunal for greenwashing. Until now, this was limited to the Competition Bureau or groups of six citizens. This opening increases the likelihood of complaints. A competitor, an NGO, a consumer—anyone can start proceedings, with the Tribunal’s approval.

Risks to Take Seriously

A validated complaint could lead to:

• Major financial penalties (up to $15 million or 3% of global revenue)
• Injunctions to withdraw misleading messages or claims
• Public corrective notices and media exposure (a direct hit to reputation)
• Erosion of stakeholder trust

And all of this, even if the company acted in good faith.

Greenhushing: A False Good Idea

In response to this law, several companies have already started pulling or reducing their environmental communications. This is called greenhushing: staying silent rather than risking making a mistake. It’s understandable, but unfortunate. Because you can keep talking about sustainability—if you do it right.

8 Key Steps For Compliance

Here’s what we recommend implementing quickly:

1. Validate your claims before publication, with proof in hand
2. Raise awareness among your teams and train your spokespeople
3. Consider the overall impression: even a truthful statement can be perceived as misleading or exaggerated
4. Avoid vague terms without support (e.g., “eco-friendly,” “sustainable,” “good for the planet”)
5. Audit your existing materials (website, presentations, reports, social media)
6. For international groups, adapt global messaging to Canadian requirements
7. Be transparent when revising your ESG targets: better to explain than to erase
8. Involve ESG teams in your campaigns and formalize a validation process
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‍A Constraint That Can Become a Lever

Yes, Bill C-59 adds pressure. But it can also be an opportunity to truly review your messages, strengthen coherence between your commitments, your actions, and your communications. It’s also a way to mobilize your teams and set yourself apart through rigor. At Casacom, we firmly believe this rigor can become a credibility lever. And we’re here to help you navigate it, without falling into excessive caution—or into the trap of inaccuracy.

*Act to implement certain provisions of the 2023 Fall Economic Statement tabled in Parliament on November 21, 2023, and certain provisions of the budget tabled in Parliament on March 28, 2023; articles 74.01(1)(b.1) and (b.2).

Disclaimer: This article is for general information only. It does not constitute legal advice and does not replace consultation with a lawyer. While the content is based on reliable and up-to-date sources at the time of writing, Casacom is not a provider of legal services.