Checklist · Climate, ESG & Sustainability Reporting

Greenwashing review checklist for environmental and sustainability claims

Pre-publication checklist for environmental, climate and sustainability claims in marketing, product disclosure and corporate reporting, mapped to the ACCC's eight principles, the ASIC greenwashing guidance and the misleading conduct provisions.

Kind
Checklist. Steps or checks to work through and tick off.
Where it applies
Australia
AI use
Red Keep AI out of the decisive steps. A lawyer does the work.
Law stated as at
17 October 2026
Status
Maintained. Checked on 17 October 2026 against the 8 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Use before a client publishes environmental or sustainability claims about products, services, financial products or the business. Not a substitute for substantiation evidence or for advice on product disclosure document content.

How AI may be used

Lawyer-led for the judgment. AI may collect claims from identified materials and list the evidence the client holds beside each one, but whether a claim is misleading or adequately substantiated is a legal judgment.

AI may

  • Extract every environmental or sustainability claim from the pages, decks or documents the lawyer identifies, with location references.
  • List beside each claim the evidence the client says supports it, and flag claims with no evidence listed.
  • Flag broad or absolute terms (for example 'green', 'sustainable', 'carbon neutral', 'net zero') for the lawyer's attention.

AI must not

  • Must not decide whether a claim is misleading, substantiated or compliant.
  • Must not rewrite claims for publication without lawyer review.
  • Must not create or summarise scientific or certification evidence the client has not supplied.

The lawyer checks

  • Each claim's overall impression to the ordinary consumer or investor, including visuals.
  • Evidence is current, relevant to the claim's scope and, where possible, independent.
  • Future claims (targets, net zero) have reasonable grounds and a documented plan.
  • Consistency with the sustainability report, PDS, ASX announcements and website.

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

Authorities

Official form

Open the official form. Always use the current version from the issuer.

Read the full text

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