The legal architecture of sustainable finance: a comparative analysis of green finance taxonomies in emerging and developed economies

In response to escalating climate and social imperatives, sustainable finance has become a key instrument for reallocating capital toward environmentally sustainable activities. Central to this transition are green finance taxonomies, which establish classification frameworks to determine the environmental sustainability of economic activities. Despite their growing prominence, significant disparities persist in the design and application of such taxonomies across jurisdictions, particularly between developed and emerging economies. This article offers a comparative legal analysis of green finance taxonomies within the European Union, China, South Africa, and selected ASEAN and Latin American states. This research adopts a doctrinal legal methodology, relying on comparative legal analysis of regulatory texts, policy documents, and legal related to green finance taxonomies. The analysis draws on statutory documents, official taxonomies, and secondary legal literature. The article critically examines the extent to which legal and institutional architectures support the integrity, enforceability, and functionality of these frameworks, particularly in addressing greenwashing and promoting transparency. The analysis underscores the divergence between binding legal instruments in advanced economies and voluntary or hybrid mechanisms prevalent in developing jurisdictions. It posits that legal enforceability, regulatory harmonization, and institutional coherence are essential to fostering credible and effective green finance ecosystems. The paper concludes that green taxonomies must extend beyond technical classification systems to encompass robust legal frameworks that ensure accountability, market trust, and cross-border financial integration. These findings offer critical implications for policymakers, regulatory authorities, and financial institutions seeking to operationalize sustainable finance through legally grounded and globally coherent taxonomies.