This article starts with the observation that in the study and practice of global environmental governance (GEG) institutions and organizations are often conflated. For regime theorists they are not the same thing and the argument is advanced that, despite its failings, the regime/institutional approach continues to have significant analytical advantages. However, the benefits of regime analysis can only be realized if it avoids becoming an arena for inter-governmental rational choice theorizing and takes institutions seriously. One way of doing this is to utilize John Searle's “general theory of institutional facts.” Searle's work provides the inspiration for a re-consideration of the bases, components, domain and explanation of global environmental regimes. It is argued that it could yield a new institutional approach which overcomes some of the problems of existing regime analyses in ways appropriate to the study of multilevel environmental governance.