Compliance Briefing — May 31, 2024

Executive briefing: From 31 May 2024 the UK Financial Conduct Authority’s anti-greenwashing rule (ESG Sourcebook 4.3.1R) applies to all FCA-authorised firms. Sustainability references in marketing, product documentation, or financial promotions must be accurate, substantiated, and presented proportionately.

Key compliance checkpoints

• Evidence-based claims. Substantiate environmental and social statements with data, methodologies, and limitations before publication.
• Governance. Embed review and approval processes for sustainability claims across marketing, product, and investor communications.
• Ongoing monitoring. Reassess claims when products, benchmarks, or ESG strategies change to maintain accuracy.

Operational priorities

• Training. Educate marketing, product, and client-facing teams on the FCA’s four fairness outcomes: correct, clear, complete, and contextual.
• Inventory. Audit existing communications, website content, factsheets, and ESG reports to remediate unsubstantiated claims.
• Documentation. Maintain records linking sustainability claims to underlying evidence and approvals.

Enablement moves

• Integrate anti-greenwashing checks into product governance committees and financial promotion sign-off.
• Deploy content management workflows with mandatory attestations for ESG statements.
• Coordinate with Consumer Duty initiatives to ensure consistent, outcome-focused disclosures.

Sources

• FCA Policy Statement PS23/16
• FCA Finalised Guidance FG24/3 on anti-greenwashing

Zeph Tech helps firms operationalise the anti-greenwashing rule with claim inventories, evidencing frameworks, and governance workflows.

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