Feedback Statement on Anti-Greenwashing Guidance and Code of Corporate Governance Update

The Commission has today published a Feedback Statement following consultation on measures aimed at clarifying sustainability practices within the Bailiwick’s financial sector.

The statement outlines the Commission’s response to feedback received on:

• A new Guidance Note on Anti-Greenwashing, which clarifies existing obligations under the Minimum Criteria for Licensing. The guidance makes clear that all licensed entities must ensure any references to environmental sustainability characteristics in communications are fair, clear and not misleading and consistent with the actual attributes of the product or service.

• Updates to the Finance Sector Code of Corporate Governance to expand the current expectation for boards to consider climate-related risks, extending it to encompass broader environmental sustainability risks, including climate change and biodiversity.

Both measures reflect the Bailiwick’s commitment to maintaining its reputation as a forward-thinking and responsible international financial centre, while avoiding unnecessary burdens on well-managed firms. Instead, they codify expectations that responsible businesses already meet.

The new Guidance Note and amendments to the Code will come into force on 1 February 2026.

The Commission would like to thank all persons who responded to both the Consultation and Discussion Papers.