The Financial Conduct Authority (FCA) will continue to focus on 'greenwashing' (i.e., misleading claims made about the environmental credentials of an organisation/product). On 31 May 2024, the FCA's anti-greenwashing rule (AGR) came into force. While the FCA already prohibited misleading statements, firms must ensure that environmental/social statements made to their 'audience' in the UK about their financial products/services are consistent with that product/service, fair, clear and not misleading. Failure to do so could result in enforcement action. As we have previously predicted, enforcement taken under the AGR regime may also encourage additional disputes (including shareholder litigation) and investigations by other regulators.




