Rapidly increasing enforcement against environmental and sustainability claims
UK regulators have entered a new phase of coordinated scrutiny on sustainability-related claims.
Which regulatory bodies are enforcing the sustainability claims standards?
The Financial Conduct Authority’s (FCA) anti-greenwashing rule now applies to all authorised firms, alongside the new Sustainability Disclosure Requirements (SDR) for labelling, naming and marketing rules already in force for asset managers.
Meanwhile, the Competition and Markets Authority (CMA) gained direct fining powers (up to 10% of global turnover) on 6 April 2025 under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), with green claims prioritised for early enforcement.
The Advertising Standards Agency (ASA) also continues to clamp down on unsubstantiated environmental claims, issuing updated guidance and rulings throughout 2025–26.
How could the crackdown on green claims impact your marketing strategy?
Any sustainability-related messaging (marketing, reporting, investor decks, website copy, product literature or even imagery) now carries material regulatory, litigation and reputational risk. The FCA expects claims to be fair, clear and not misleading, with evidence and internal approvals mirroring those used for financial disclosures. The CMA’s new powers mean that weaknesses in substantiation, vague claims or omission of context can now trigger direct enforcement, accelerated investigations and significant fines. ASA decisions continue to shape acceptable wording - particularly around life-cycle impacts and absolute claims.
Businesses may need to tighten internal governance, update approval flows, revisit product messaging, and ensure that evidence packs exist for every sustainability claim.
What steps can businesses take to ensure their environmental claims are compliant?
Businesses need to act quickly, as regulators are already in supervisory mode. Create or update a central claims register, build evidence files for all sustainability statements, and ensure all marketing and communications teams follow a formal green-claims review process. Teams should be trained on CMA, FCA and ASA expectations - especially the requirement to avoid broad, absolute or misleading impressions created by visuals or headlines.
Failure to act could result in significant regulatory intervention, product relabelling, campaign withdrawal, compulsory corrections, or (under the CMA regime) substantial penalties and reputational fallout.
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Please be advised that this is an update which we think may be of general interest to our wider client base. The insights are not intended to be exhaustive or targeted at specific sectors as such, and whilst we naturally take every care in putting our articles together, they should not be considered a substitute for obtaining proper legal advice on key issues which your business may face.