New Zealand’s financial markets regulator has published revised disclosure standards for issuers of products marketed on sustainability grounds, setting out what they must tell investors and how they must say it. The Financial Markets Authority – Te Mana Tātai Hokohoko (FMA) released the document on May 12, 2026, under the title Sustainability-Related Disclosure Guidance. The rules apply broadly across the financial sector, covering managed funds, bonds, and other products that carry environmental, social, or values-based labels. The guidance is relevant wherever products are positioned using sustainability criteria – including investment-linked offerings and KiwiSaver funds managed by insurers. The document supersedes two older FMA publications: the 2020 Disclosure Framework for Integrated Financial Products and the review observations from the 2022 Integrated Financial Products: Review of Managed Fund Documentation.
The FMA has built the guidance around four obligations: that claims be clear, that claims be backed by evidence, that messaging be consistent across channels, and that relationships with external parties be properly disclosed and managed. FMA executive director of response and enforcement Louise Unger described the purpose of the update. “The updated guidance supports issuers to provide investors with clear and accessible information on financial products with sustainability-related characteristics, such as environmental, social, or value-based considerations, so investors can be confident that what they are investing in aligns with their investment objectives,” Unger said. The regulator noted that the four underlying principles were carried over from an earlier draft that went through a public consultation process, though the language and structure were revised in response to submissions.
The FMA’s first principle targets the quality of sustainability-related language. Issuers must communicate in terms that an ordinary investor – not a specialist – can follow. Where an issuer uses categorical language, such as stating that a fund “never” holds certain assets, there should be no carve-outs that contradict that claim. Critically, the FMA’s standard is not limited to what is written. How information is visually presented – its layout, prominence, and the relative weight given to positive versus qualifying information – can determine whether the overall impression is accurate or misleading. An omission carries the same regulatory weight as a false statement if it skews what an investor is likely to understand.
The guidance gives detailed attention to screening strategies. Issuers running negative screens – excluding companies, sectors, or activities from a portfolio – must disclose the boundaries of those screens: what is excluded and why, the revenue or ownership thresholds applied, and how the screening is carried out and monitored. The same level of specificity applies to positive screening, where the fund deliberately targets companies with strong sustainability outcomes.
Issuers claiming a stewardship role – for example, using shareholder voting rights or direct company engagement to influence environmental or social outcomes – are required to describe what that means in practice. The guidance cautions against language that implies a level of influence that exceeds what the issuer can realistically demonstrate. The FMA also addressed the growing use of te reo Māori and Māori concepts in product marketing. Issuers drawing on indigenous values or terminology must explain what those terms mean to a general investor audience, describe how those values translate into actual investment decisions, and not imply Māori ownership or iwi endorsement unless that is factually the case.
The second principle requires that issuers have a factual basis for any sustainability-related representation at the point it is made. Stating an intention or aspiration without supporting material does not satisfy the standard. On product labelling, the FMA observed that terms such as “green,” “sustainable,” or “social” signal to investors that sustainability is a central purpose of the product, not a secondary consideration. No New Zealand regulation currently specifies when such terms can or cannot be applied, but the guidance holds issuers to the same evidential standard regardless of whether a formal label is used. Third-party assurance – such as an independent review of a product's alignment with international standards or external verification of sustainability targets – can strengthen an issuer’s position, but only if the nature of that assurance is properly disclosed. The FMA expects issuers to identify who conducted the review, what it covered, when it was carried out, and whether the results are accessible to investors.
The third principle addresses a practical problem: issuers communicate with investors across many formats – PDSs, SIPOs, websites, email, social media, and advertising – and the same product can be described in substantially different terms across those channels. “It’s important that investors have the information they need to understand the nature of the sustainability-related claims made about a product so they can make well-informed decisions about their investments,” Unger said. The FMA’s position is that a correction buried in a footnote or follow-up document cannot fix a misleading headline. If an advertising claim overstates what a product does, that is a problem at the point the advertising runs – not something that can be resolved by later clarification.
For managed investment schemes specifically, the SIPO must stand alone as a complete account of the fund's investment policy. Issuers cannot rely on their website to carry key information that is absent from statutory documents, both because websites can be altered without regulatory notification and because website content alone does not fulfil disclosure obligations under the Financial Markets Conduct Act 2013 (FMC Act). Where issuers use derivatives within a fund that is marketed on sustainability grounds, the guidance requires consideration of whether the derivative exposure creates indirect holdings in assets the fund claims to exclude. If it does, that must be disclosed.
The fourth principle covers what happens when an issuer delegates part of its sustainability process to an outside provider – whether a data vendor, a third-party fund manager, or a certification body. The FMA’s position is that delegation does not transfer regulatory responsibility. Issuers are expected to have internal processes in place to verify that external providers are performing as described, that data used in screening is accurate, and that the messaging produced by those providers aligns with what the issuer has committed to in its own documents. Where a third-party manager runs an underlying fund within a larger structure, issuers must consider whether differences between their own sustainability policy and the underlying manager’s approach need to be disclosed to investors.
The FMA stated that the document is not intended to tell issuers how to invest, nor does it define what constitutes a sustainable investment in substantive terms. Its scope is confined to how issuers represent their products. While the guidance is directed primarily at products sold to retail investors, the FMA noted that wholesale issuers should consider its principles as applicable to their own disclosure practices. Enforcement action for any given disclosure will be assessed against the specific facts and circumstances involved.
