CMA’s green claims crackdown for investors

Earlier this year, the Competition and Markets Authority (CMA) published updated guidance that fundamentally shifts liability for environmental claims across supply chains, sending a clear message to businesses: good intentions won’t protect you from enforcement.

For investment teams making sustainability claims about portfolio companies, the question isn’t what you said – it’s what you can prove.

The regulatory reality check

In January 2026, the CMA published updated guidance that fundamentally shifts liability across supply chains, and the implications for asset managers are significant. The regulator now holds both retailers and brands responsible for repeating unverified supplier claims about environmental performance.

Translation for investment teams: if your engagement reports, stewardship disclosures, or client communications claim progress on ESG metrics based on company assertions alone, you’re exposed.

The CMA’s position is unambiguous:

• Vague claims like “net zero aligned” or “sustainable supply chain” require robust, verifiable evidence.
• Third-party data cannot be repeated without independent verification.
• Governance processes must be documented and audit-ready

This isn’t theoretical. The CMA has already launched investigations into major retailers and fashion brands. Asset managers promoting stewardship activities without evidentiary trails could be next.

Why this matters for investment teams

Your team engages hundreds of companies annually on climate targets, biodiversity commitments, and social metrics. You report progress to clients, regulators, and internal governance committees. But how defensible is that evidence chain?

Consider the typical workflow:

1. Company makes a commitment (e.g., “deforestation-free by 2030”)
2. Your team logs the engagement
3. Progress is reported based on company disclosures
4. Stewardship claims are made in client reports and regulatory filings

The gap: Where’s the verification? Where’s the audit trail showing you challenged, tracked, and validated those claims against measurable KPIs?

Under the CMA’s framework, and increasingly under FCA and ISSB requirements, that gap is a compliance risk.

From intentions to evidence

Robust engagement governance requires three things:

1. Structured engagement tracking
Every interaction needs to be logged against specific, measurable objectives (not free-text notes buried in spreadsheets!) You need to show what was requested, when, and what was delivered.

2. KPI-based progress monitoring
Company commitments must be translated into trackable metrics with clear timelines. “Working towards net zero” isn’t evidence. “Scope 1+2 emissions reduced 15% YoY against 2023 baseline, verified by CDP disclosure” is.

3. Audit-ready reporting
When the FCA, CMA, or a client asks “how do you know?”, you need instant access to engagement letters, company responses, progress dashboards, and escalation histories, not a two-week scramble through email chains.

How SI Engage closes the evidence gap

SI Engage was built for this very challenge. Our platform transforms engagement intentions into defensible evidence:

• Centralised engagement repository: Every company interaction, commitment, and follow-up is logged, timestamped, and linked to specific ESG KPIs
• Progress tracking against targets: Monitor company performance against agreed milestones with automated reminders and escalation workflows
• Instant report generation: Produce audit-ready stewardship reports for clients, regulators, or internal governance committees in clicks, not weeks
• Collaborative workflows: Ensure consistency across your team with shared templates, approval chains, and version control

The result? When scrutiny comes, and it will, you’re not defending intentions. You’re presenting evidence.

Three actions to take this week

1. Audit your current claims: Review client reports, stewardship disclosures, and marketing materials. Which claims rely on unverified company assertions?
2. Map your evidence chain: For each active engagement, ask: “Could we prove this tomorrow if challenged?” If the answer involves email searches or spreadsheet hunts, you have a gap.
3. Centralise your governance: Move from fragmented tools (spreadsheets, email, shared drives) to a single platform built for engagement evidence and audit readiness.

The CMA’s green claims guidance isn’t just a retail problem. It’s an investment team problem. And as regulatory scrutiny intensifies across the value chain, the difference between compliant and exposed comes down to one thing: evidence.

SI Engage helps you build it; systematically, defensibly, and at scale.

Want to see how SI Engage transforms engagement tracking from administrative burden to compliance asset? Get in touch for a demo!