First announced: FCA published finalised non-handbook guidance (FG24/3) and the anti-greenwashing rule guidance around Nov 2023; the rule came into force 31 May 2024.
Submitted by: NYBACS Compliance Desk
The FCA introduced a bespoke anti-greenwashing rule and final guidance (FG24/3) — published in late 2023; the rule took effect 31 May 2024.
Firms must ensure sustainability claims are fair, clear and evidential.
Funds, advisers and marketers should review product naming, marketing and disclosure practices.
What changed: The Financial Conduct Authority finalised anti-greenwashing guidance and an explicit anti-greenwashing rule (guidance FG24/3 was published in late 2023) to prevent misleading sustainability claims for financial products; the rule came into force 31 May 2024. This requires firms to ensure any sustainability statements are substantiated, not misleading, and consistent with the product’s design and outcomes.
Who’s affected: FCA-authorised firms (asset managers, fund promoters, advisers and retail distributors) using ESG/ sustainability statements in product documentation or marketing.
Immediate actions (NYBACS checklist):
- Audit sustainability claims across products and marketing materials for veracity and documentary backing.
- Implement a governance sign-off for ESG claims (document evidence, metrics and monitoring).
- Train marketing, compliance and product teams on the FCA examples of good/poor practice.
Practical notes: The FCA also published examples of good/poor practice; firms should retain evidence to demonstrate claims are substantiated and have monitoring frameworks in place. FCA+1
