In the past few years, the number of lenders adopting voluntary environmental codes, such as the Equator Principles, is increasing. The main reasons for this form of over-compliance include warm glow preferences of agents, credit risk and incentives arising from regulation. Empirical evidence suggests that lenders that over-comply are generally bigger than those that don’t. In particular, they are likely to be MNCs. In addition, the behaviour of overcomplying lenders differs from other lenders, for instance they are more likely to incorporate environmental risks in their lending practises. In the context of developing countries, incentives that promote over-compliance exist to a much lesser degree. Analysing the regulatory environment in developing countries, we find no compelling reason for regulators to encourage voluntary initiatives such as the Equator Principles.