For all the talk of how important ESG considerations are to real estate investors, when it comes to national regulations that force the issue, the world is an uneven place, says a new report from real estate intelligence and analysis firm Green Street. And right now, the US is far behind Europe.

"Climate-related regulations are not a far-off possibility, but a near-term reality in the U.S. and Europe," writes the firm. "Regulations relating to climate change are varied and extensive. However, a common framework, particularly towards commercial real estate, undergirds most laws, enabling comparisons between the US and Europe. Not surprisingly, Europe is generally several steps ahead on this issue relative to even the most aggressive US regulatory body." 

The firm looked at regulations across top markets in Europe and in the US, with a "scoring framework … designed to measure the potential impact on value/NOI." The scoring scale was from 0 to 100. The average in European markets was 66. In the U.S. it was 11, including the "most aggressive U.S. regulatory body." Most U.S. markets have few regulations, like the Sun Belt which has been the recipient of significant demographic shifts, unlike Europe.