What changed
The UK has a dual enforcement framework: CMA handles consumer-facing claims, FCA addresses financial services sustainability claims. Both moved from guidance to active enforcement in 2024-2025.
CMA enforcement
From April 2025, the CMA can directly impose fines of up to 10% of global annual turnover without going through courts. The CMA has conducted sector-wide reviews in fashion, FMCG, and food.
FCA enforcement
The FCA’s anti-greenwashing rule (effective May 2024) requires all sustainability claims to be fair, clear, and not misleading. The FCA has indicated it will proactively review marketing materials.
What companies should do now
Audit all consumer-facing claims against the CMA’s Green Claims Code. Financial services firms should review all sustainability marketing against SDR requirements.