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Abstract
This article examines the emergence of green sukuk as an instrument situated at the intersection of
Islamic finance, sustainable finance, and comparative financial regulation, with particular reference
to the Organization of Islamic Cooperation (OIC) and the European Union (EU). The study argues
that green sukuk may represent a distinctive mechanism for financing sustainable development
because they combine Sharia-compliant financial structures with environmental, social, and
governance (ESG) objectives, thereby linking ethical finance to climate-transition strategies. After
outlining the legal and operational characteristics of sukuk and their evolution within Islamic
finance doctrine and AAOIFI standards, the article analyses the increasing role of green sukuk in
financing renewable energy, climate adaptation, and sustainable infrastructure projects across OIC
jurisdictions, particularly in Malaysia, Indonesia, Saudi Arabia, and the Gulf region. The article
then explores the European dimension of sustainable Islamic finance through the lens of the
European Green Deal, the EU Taxonomy Regulation, and the “Do No Significant Harm” principle,
underscoring convergences and tensions between EU sustainability regulation and Sharia
governance.
Adopting a comparative-law methodology, the article highlights how green sukuk serves as a
privileged vantage point for analyzing the broader transformation of contemporary financial law
into a plural and transnational normative space.
Finally, the article analyses the central role of the doctrinal formant in shaping Islamic financial law,
focusing on AAOIFI Sharia Standard No. 62 and the transition from asset-based to asset-backed
sukuk structures. It is argued that the future credibility of green sukuk markets depends upon the
development of transnational governance mechanisms capable of preventing both greenwashing and
“Sharia-washing” through stronger disclosure, environmental oversight, and interdisciplinary
expertise. The article concludes that green sukuk may constitute an important component of global
sustainable finance, provided that regulatory harmonization, secondary-market development, and
integrated Sharia-environmental governance continue to evolve within an increasingly transnational
legal framework.
