Form · Climate, ESG & Sustainability Reporting

Environmental claim substantiation record (one claim, its evidence and the sign-off)

A record kept for each environmental or sustainability claim before it is published: the exact words and context, the impression it gives, the evidence and its date, qualifications, future-matter grounds, and the legal sign-off, structured around the ACCC's eight principles.

Kind
Form. A form to complete, or a guide to completing an official one.
Where it applies
Australia
AI use
Red Keep AI out of the decisive steps. A lawyer does the work.
Law stated as at
18 October 2026
Status
Maintained. Checked on 18 October 2026 against the 3 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Use for each new or renewed environmental claim in advertising, packaging, websites, social media, investor material or sales scripts (for example "carbon neutral", "recyclable", "net zero by 2040"). Keep it on file so the business can show its basis for the claim if the ACCC, ASIC or a competitor asks.

Used for these tasks

Each task page says how far AI may help with the task and what the lawyer must review.

How AI may be used

AI may collect the claim's wording, placements and the documents offered as evidence; a lawyer decides what the claim conveys, whether the evidence substantiates it and whether it can be published.

AI may

  • Collect every placement of the claim from the marketing files supplied and record the exact words and context
  • Index the evidence documents with their dates, authors and scope, and flag evidence older than the review date
  • List qualifications that appear in the evidence but not near the claim

AI must not

  • Must not decide the overall impression the claim conveys to ordinary consumers or investors
  • Must not conclude that the evidence substantiates the claim, or that a future claim has reasonable grounds
  • Must not suggest alternative claim wording for publication
  • Must not complete the sign-off section

The lawyer checks

  • The impression conveyed has been assessed in its full context, including images, logos and colours (Principle 7)
  • The evidence is current, covers the whole of what is claimed and, where relevant, is independent and scientific (Principle 2)
  • A future claim (target, commitment or forecast) has documented reasonable grounds, including a plan and resources (ACL s 4)
  • Qualifications are clear and prominent, and the claim is not broad or unqualified (Principles 4 and 5)

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Read the full text

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