Compliance Briefing — May 31, 2024
The FCA’s anti-greenwashing rule is now in force, requiring all authorised firms to ensure sustainability-related claims are fair, clear, and not misleading across products and communications.
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
Zeph Tech helps firms operationalise the anti-greenwashing rule with claim inventories, evidencing frameworks, and governance workflows.