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Vedder Thinking | Articles Citing “Greenwashing” Concerns, IOSCO Issues Recommendations to Securities Regulators on Sustainability-Related Practices, Policies and Disclosures


Reader View

On June 30, 2021, the International Organization of Securities Commissions (IOSCO)—which counts the SEC among its members—issued a consultation report recommending that securities regulators set regulatory and supervisory expectations for asset managers regarding sustainability-related risks and opportunities. 

IOSCO’s recommendations to securities regulators covered five areas:

  1. Asset Manager Practices, Policies, Procedures and Disclosures. Set regulatory and supervisory expectations for asset managers with respect to sustainability-related practices, policies, procedures and disclosures.

  2. Product Disclosure. Clarify and/or expand existing regulatory requirements or create new regulatory requirements to improve sustainability-related product disclosure.

  3. Supervision and Enforcement. Adopt supervisory and enforcement tools to ensure asset managers and sustainability-related products comply with regulatory requirements and to address breaches.

  4. Terminology. Encourage industry participants to develop common sustainability-related terminology to ensure consistency in the asset management industry.

  5. Financial and Investor Education. Promote financial and investor education initiatives relating to sustainability and enhance existing initiatives.

The foregoing recommendations are intended to address IOSCO’s concerns regarding “greenwashing,” among other things.  Greenwashing generally refers to the practice by asset managers of misrepresenting their own sustainability-related practices or the sustainability-related features of their investment products.  IOSCO’s report emphasized the investor protection-related concerns with greenwashing given the significant growth in the market for sustainability-related investment products.

The Board of IOSCO invited market participants and interested parties to submit comments on the report on or before August 15, 2021.

IOSCO’s consultation report is available here.


John S. Marten


Nathaniel Segal


Jacob C. Tiedt


Jake W. Wiesen