How confident are you in the credibility of your sustainability claims?
Preventing greenwashing: A practical playbook for meeting regulatory expectations
How confident are you in the credibility of your sustainability claims?
As the bar for sustainability claims rises, Swiss financial institutions are under increasing pressure to ensure their ESG statements are not only accurate but also consistent and independently verifiable. Frameworks like FINMA Guidance 05/2021, SBA and AMAS self-regulation, the revised UWG Art. 3, and the EU Empowering Consumers Directive for EU markets, collectively set clearer standards for honest communication, robust governance, and greater accountability. They demand that sustainability claims are backed by evidence, thoroughly documented, and aligned with both internal processes and external disclosures.
Greenwashing risks can emerge throughout the value chain, from the institutional level to product level and at the point of sale. Preventing greenwashing should be integrated into governance, risk management, product design, advisory discussions, marketing, reporting, and financing. Without clear responsibilities, strong controls, consistent language, staff training, and documented oversight, institutions face increased regulatory, legal, and reputational risks.
A comprehensive anti-greenwashing framework is crucial to maintain trust and meet supervisory expectations.
We assist financial institutions in designing and implementing an Anti-Greenwashing Playbook that combines governance structures, ESG data controls, product oversight, client-facing processes, and communication standards. Our tailored approach helps institutions build internal resilience, align with regulations, and clearly demonstrate the credibility of their sustainability commitments.
Our service offering: Implementing the Anti-Greenwashing Playbook
We assist financial institutions in meeting anti-greenwashing standards by creating a reliable, audit-ready framework that spans governance, products, point of sale, distribution financing, reporting, and communication.
- Review of the current greenwashing risk management, incl. governance, ESG data, product documentation, marketing, distribution practices, and financing workflows.
- Review and flagging of potentially critical claims and disclosures.
- Identification of inconsistencies across strategy, product and corporate disclosures, and regulatory expectations (including review of net-zero and transition strategies against respective claims).
- Development of a comprehensive Playbook with governance roles, processes, and controls.
- Integration of requirements across product governance, disclosure, risk management, and ESG data validation.
- Definition of specific anti-greenwashing controls across investment product governance, financing and credit criteria, ESG‑claim substantiation, client‑preference alignment, distribution, and corporate disclosures.
- Integration into ICS and early warning system.
- Harmonisation of sustainability claims across marketing, website content, disclosures, and reports, establishment of review processes.
- Tailored training and staff guidelines with checklists to ensure ongoing compliance.
Why choose us?
In-depth greenwashing regulatory knowledge
We have extensive expertise in Swiss and European anti-greenwashing and sustainability requirements.
Comprehensive anti-greenwashing approach
Our playbook integrates governance, product oversight, point of sale, marketing, disclosures, ESG data, and controls.
Proven methods and tools
We offer practical checklists, review workflows, internal controls, and data-quality frameworks.
Effective implementation
We transform regulatory expectations into actionable processes, training, and monitoring.
Global network, local swiss expertise
Our strong local expertise is backed by international sustainability and regulatory capabilities.
Contact us
Partner, Sustainable Capital and Sustainability & Strategic Regulatory Leader, PwC Switzerland
+41 79 267 84 89
Patrick Schmucki
Rahel Blumer
Tina Minci