The FCA has recently published a Consultation Paper (CP22/20) aimed at addressing its “growing concerns that firms may be making exaggerated, misleading or unsubstantiated sustainability-related claims about their products; claims that don’t stand up to closer scrutiny (so-called ‘greenwashing’).” This follows the November 2021 Discussion Paper (DP21/4), concerning the FCA’s proposed approach to UK Sustainability Disclosure Requirements (“SDRs”) and a sustainable investment labelling system. More generally, the FCA has consistently emphasised its determination to combat greenwashing in recent times.
In the Consultation Paper, the FCA focuses on (i) specific sustainable investment labels, (ii) qualifying criteria required to use one of these labels, (iii) product- and entity-level disclosures, and (iv) naming and marketing rules. The FCA is clear, however, that these are only a “starting point” for an expanding and evolving regime.
November 8, 2022
