AI Governance: Building a Defensible Governance Framework — 22 Apr

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FCA Anti-Greenwashing Rule now in force

Every sustainability claim. 
Verified before publication.

Submit, screen, evidence, and approve green claims against FCA, CMA, and EU regulatory requirements — with full audit trail and AI-assisted risk detection.

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Document & Policy Vault
FCA FG24/3— Compliant
CMA Code— 6 Principles
EU GCD— Ready
Full Audit Trail— 7-year retention
The Regulatory Reality

Greenwashing enforcement has arrived

The FCA's Anti-Greenwashing Rule (FG24/3) applies to every sustainability-related claim made by FCA-authorised firms — in marketing, fund documentation, product labels, and client communications. Meanwhile, the CMA is actively investigating consumer-facing green claims under its Green Claims Code.

£3.4M

Average FCA fine for misleading financial promotions (2024)

73%

Of firms lack a formal process for verifying sustainability claims

6

CMA Green Claims Code principles — each requiring documented evidence

Workflow

From claim to audit-ready in five steps

Every step produces an immutable audit record. No claim reaches publication without structured verification.

STEP 01

Claim submitted for verification

Marketing, legal, or product teams submit the exact claim text, select the applicable framework (FCA, CMA, EU GCD), and tag lifecycle scope stages per CMA Principle 5.

Claim enters the registry as DRAFT with full metadata captured from day one.

CLM-004

Draft

"Our packaging is made from 100% post-consumer recycled material"

CMA Green Claims Code
Raw Materials
Manufacturing

Regulatory Coverage

Built for the regulations that matter

Every checklist item maps to a specific regulatory paragraph. No generic tick-boxes — real compliance traceability.

FCA Anti-Greenwashing Rule

  • correct

    Fair, clear, and not misleading standard

  • correct

    Applies to all sustainability-related claims

  • correct

    Covers marketing, labels, and client comms

  • correct

    Claims must be substantiated at point of making

CMA Green Claims Code

  • correct

    Truthful and accurate claims

  • correct

    Clear and unambiguous language

  • correct

    No omission of important information

  • correct

    Full lifecycle consideration (Principle 5)

  • correct

    Fair and meaningful comparisons

  • correct

    Substantiation with robust evidence

EU Green Claims Directive

  • correct

    Third-party verification of claims

  • correct

    Standardised substantiation methodology

  • correct

    Ban on generic environmental claims

  • correct

    Lifecycle assessment requirements

Regulatory Timeline

What's in force, what's coming

FCA Anti-Greenwashing Rule

FG24/3 in force — all FCA-authorised firms must ensure sustainability claims are fair, clear, and not misleading.

CMA Enforcement Actions

CMA actively investigating misleading green claims under Consumer Protection from Unfair Trading Regulations 2008.

EU Green Claims Directive

Substantiation and pre-approval requirements for environmental claims to EU consumers.

EUDR Full Enforcement

EU Deforestation Regulation — product-level due diligence and traceability claims must be substantiated.

Connected intelligence

One registry. Every connection.

AI Governance data flows across your enterprise GRC and sustainability reporting — because every AI finding already maps to risk, controls, and disclosure.

  • AI Risk Screening

    Every claim screened against regulatory red flags. Vague language, unsubstantiated absolutes, and high-risk terms flagged automatically.

  • Regulation-Mapped Checklists

    Assessment items linked to specific FCA paragraphs and CMA principles. Not generic tick-boxes — real regulatory traceability.

  • Lifecycle Scope Tracking

    Visual lifecycle indicator (raw materials → end of life) per CMA Principle 5. Gaps flagged automatically.

  • Separation of Duties

    Claim submitter cannot approve their own claim. Four-state workflow: Draft → In Review → Approved → Locked.

  • Evidence Linking

    Every checklist item requires attached evidence. Documents linked from DocVault with verification status tracking.

  • Expiry & Re-verification

    Approved claims carry validity windows. Automatic alerts before expiry. Expired claims auto-flagged for withdrawal or re-verification.

  • Connected Intelligence

    Linked to GHG Inventory, ESG Reporting, and Regulatory Intelligence modules. Claims pull live data — not stale copies.

  • Board Reporting

    Summary view of claims pipeline, compliance posture, and risk exposure for board and audit committee packs.

  • Full Audit Trail

    Every action — submission, screening result, checklist completion, approval — logged immutably with timestamp and user identity. 7-year retention.

Who It's For

Built for the people who sign off

Head of Compliance

Oversee claim approval pipeline, ensure regulatory alignment, prepare for FCA supervisory reviews

Legal Counsel

Review AI screening flags, assess regulatory risk, approve conditional claims with documented rationale.

Marketing Lead

Submit claims with correct lifecycle scope and evidence before publication. No more last-minute legal reviews.

Board / Audit Committee

View aggregated compliance posture, outstanding conditions, and expiry risk in board pack format.

Don't wait for the enforcement action

The FCA Anti-Greenwashing Rule is live. The CMA is investigating. Get your claims governance in place before the regulator calls.

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