ASIC INFO 271
For Australian fund and super marketing teams working out how ASIC judges sustainability claims about financial products. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
ASIC INFO 271, How to avoid greenwashing when offering or promoting sustainability-related products, sets out nine questions for issuers describing financial products as sustainable, ethical or green. ASIC released it in June 2022.1,4
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the kinds of wording ASIC's INFO 271, and the examples in its advertising guide, describe as risky in sustainability claims about financial products.1,2
| Phrase or term | In practice |
|---|---|
| "Sustainable", "ethical", "green" in fund names | Labels that overstate the product's sustainability qualities, particularly in absolute terms. |
| "Responsible", "impact", "ESG-focused" | Broad statements or jargon used without clarifying information. |
| "We do not invest in", "eliminate" | Exclusions described as absolute when holdings remain, in a case ASIC describes. |
| "Researched and screened" | Screening claims when most holdings were not screened, in another ASIC example. |
| "Net zero by 2050" | Targets stated without a clear, time-based plan behind them, ASIC has said. |
| Sustainability metrics and ratings | Figures shown without explaining how they are used in the product. |
| Sustainability benchmark index | Used without saying whether the issuer has influence over the index. |
The Federal Court has already ordered penalties over sustainability claims about financial products.
A superannuation trustee was ordered to pay penalties after claiming it eliminated investments in areas such as coal mining and gambling that it still held.
Where it goes wrong
One approved claim ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up using the very phrases you are trying to avoid.
"Ethical Growth excludes companies earning over 10% of revenue from thermal coal."
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
Well past the PDS. ASIC's advertising guide applies to promotions in any medium, social media included,2 and we usually find sustainability wording in:
Approve each screen with its thresholds attached, and treat the thresholds as part of the claim. In an example in RG 234, a fund used words like "we do not invest" and "eliminate" without qualification, which the court read as full exclusion.2 Short formats are where qualifiers drop off first. More on this is on our marketing compliance page.
One record per claim: the approved wording, the screen or metric behind it, the thresholds and exceptions, the data date, who approved it and where it appears. INFO 271 asks issuers whether they have explained how they use sustainability metrics,1 and a record like this is the quickest way to answer. Review it whenever the portfolio or the screen changes, not only at the annual PDS update.
How it applies to a specific claim is a question for your legal adviser. Where that claim appears across your markets and languages is a question Arbitr answers.
ASIC's general advertising guide, RG 234, points to INFO 271 for greenwashing examples.2 US advisers work under the SEC Marketing Rule, and other markets are on our financial promotions hub. Claims about consumer goods in Australia fall under separate ACCC guidance, covered on our ACCC environmental claims page.
As misrepresenting the extent to which a financial product or investment strategy is environmentally friendly, sustainable or ethical, according to ASIC, which repeats that description in its June 2026 advertising guide. ASIC says greenwashing distorts information investors may need to make informed decisions.2
Most companies do, and it works for the file it reviews, in the language it reviews, before a campaign ships. It doesn't cover what's published afterwards: the market versions, the agency reworks, the sales deck built from the campaign six months later. That's a volume problem, not a failure of your legal team.
