Consultation Paper on Proposed Measures to Counter the Risk of Greenwashing

Closed 4 Jul 2022

Opened 5 May 2022



Purpose of the Consultation Paper

The Commission seeks to regulate and supervise financial services in the Bailiwick of Guernsey with integrity, proportionality and professional excellence, and in so doing help to uphold the international reputation of the Bailiwick of Guernsey as a finance centre.

The term “greenwashing” refers to the practice of misrepresenting sustainability-related practices or the sustainability related features of investment products1.

Consistent with the Commission’s objectives, the proposals in this Consultation Paper are designed to enhance levels of confidence in the Bailiwick’s regulatory and supervisory framework for investment firms and collective investment schemes by reinforcing the Commission’s expectations relating to disclosure requirements in order to help mitigate the potential risks of greenwashing.

The purpose of this Consultation Paper is to seek feedback from all interested parties on detailed proposals for the introduction of:

  1. Proposed new Guidance to be made under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (“the POI Law”).  The proposed new Guidance, sets out the Commission’s wider expectations regarding the transparency of environmental sustainability related claims and statements made in respect of Guernsey collective investment schemes which are authorised or registered under the POI Law, and
  2. Proposed additional Guidance to be added to the Licensees (Conduct of Business) Rules and Guidance, 2021, clarifying the Commission’s expectations in respect of promotion and advertising by persons licensed under the POI Law, and in particular in relation to avoiding the risks of greenwashing.

Views are also sought on the future consideration of anti-greenwashing policy measures for other supervised sectors.

Please note that a concurrent Consultation Paper covering the proposed new Natural Capital Fund regime has also been issued by the Commission (   

This Consultation Paper is a working document and does not prejudge any final decision to be made by the Commission.

What happens next

Following the consultation period, the Commission will collate and consider responses provided, with a view to introducing the Guidance Note on Reducing the Potential Risk of Greenwashing by Guernsey Regulated Collective Investment Schemes and adding the additional Guidance to the Licensees (Conduct of Business) Rules and Guidance, 2021 at some point during the second half of 2022.  


  • Consumer
  • Financial Advisor
  • Financial Services Business
  • FinTech
  • Lending, Credit & Finance Business
  • Prescribed Business
  • Lenders
  • FSPID Team
  • ExCo
  • Banks
  • Insurance Managers
  • Insurance Intermediaries