European capitalisms in sustainability transition: the case of green bonds

The EU’s sustainable finance agenda aims to accelerate the sustainability transition through the ‘greening’ of finance. How such greening may trigger institutional transformation in Member States is not well understood. However, the political economy literature has elevated the importance of non-market coordination and institutional complementarity in sustainability transitions. The article investigates sustainable finance uptake in four distinct Member States (the Netherlands, Poland, Spain and Sweden). Green bond legal documentation is analysed for three dimensions of firm-finance coordination: exchange of information, monitoring and sanctioning. The micro-level analysis identifies local adaptations that relate to how actors incorporate sustainability commitments and the EU sustainable finance rules into financial transactions and whether they conceive these as a source of risk (the Netherlands and Sweden) or a guarantee of profit (Poland and Spain). One jurisdiction (Poland) is further differentiated by a strong legal sanctioning mechanism resulting from legal factors and the presence of international financial institutions. Notwithstanding local adaptations, several micro – and meso-level transformations are identified, such as the consistent emergence of new forums for both market and non-market coordination. The political economy impacts and micro-level tensions identified in the article highlight how comparative legal analysis can anticipate the sites of broader political struggles.