Domain G · Area G-CA2 · Disclosure development, substantiation and consistency
G.7Substantiate sustainability claims and control greenwashing risk
Working Draft version 1.1
Purpose and scope
This unit covers the capability to identify explicit and implied sustainability claims and evaluate whether they are clear, specific, current, complete, balanced and supported by suitable evidence. It includes environmental, social, governance, performance, target, alignment, leadership, product, transition, assurance and comparative claims; the overall impression created by text, visuals and omissions; qualifications, dependencies and boundaries; and legal, technical and governance review.
Applied competency statement
Can identify, substantiate, qualify, revise or reject sustainability claims and evaluate greenwashing and misleading-impression risk using controlled criteria, evidence, boundaries and approval.
Boundary and escalation
This unit owns claim-by-claim substantiation, qualification and overall-impression review for sustainability communications. A.8 owns reporting-basis claim criteria and requirements traceability, F.9 owns assurance, certification and accreditation boundaries and G.11 owns post-publication monitoring and correction. The unit does not provide legal clearance or independent assurance.
Key quality risks
Vague claims such as sustainable, green, responsible, leading or net zero without criteria; cherry-picked facts; minor initiatives used to imply organisation-wide performance; claims based on future intention or purchased instruments without qualification; comparative or leadership claims without a defined comparator; certifications or assurance extended beyond their scope; imagery creating a stronger impression than the text; material adverse information omitted; outdated claims remaining on websites or marketing materials; and legal review asked only after public wording is final.
G.7-K01
Understands explicit and implied environmental, social, governance, performance, target, product, transition, comparative, leadership, alignment, assurance, certification and endorsement claims.
Knowledge Type: Claim types · Normative Weight: Core
G.7-K02
Understands clarity, specificity, relevance, completeness, accuracy, currency, boundary, period, comparator, methodology, evidence, qualification and overall-impression criteria.
Knowledge Type: Claim criteria · Normative Weight: Core
G.7-K03
Understands vagueness, omission, cherry-picking, false equivalence, halo effect, overgeneralisation, hidden trade-offs, future promise, unsupported causality, misleading imagery and scope extension.
Knowledge Type: Greenwashing mechanisms · Normative Weight: Core
G.7-K04
Understands direct and indirect support, estimates, third-party certificates, ratings, offsets, credits, exclusions, dependencies, limitations and the role of prominent qualification.
Knowledge Type: Evidence and qualification · Normative Weight: Core
G.7-K05
Understands comparator, market, period, methodology, peer set, normalisation and evidence needed for better, lower, leading, first and similar claims.
Knowledge Type: Comparative and leadership claims · Normative Weight: Core
G.7-K06
Understands claim ownership, legal and specialist review, approval, monitoring, correction, website and campaign reuse and the distinction from assurance, certification and endorsement.
Knowledge Type: Governance and boundary · Normative Weight: Core
G.7-S01
Identify and classify explicit and implied claims across text, metrics, visuals, headings, footnotes, websites and external submissions.
Skill Type: Core applied capability · Observable Output or Result: Sustainability claims register and classification
G.7-S02
Test each material claim against evidence, criteria, boundary, period, methodology, comparator, dependencies and overall impression.
Skill Type: Substantiation review · Observable Output or Result: Claim substantiation and qualification file
G.7-S03
Evaluate omission, prominence, imagery, aggregation, selective examples, future promises and the combined impression of the communication.
Skill Type: Greenwashing analysis · Observable Output or Result: Greenwashing and misleading-impression assessment
G.7-S04
Draft or recommend clear qualifications, scope, limitations and alternative wording or reject claims that cannot be supported.
Skill Type: Qualification and revision · Observable Output or Result: Claim revision and qualification record
G.7-S05
Coordinate owner, specialist, legal and governance approval and monitor claims for expiry, changed evidence, reuse and correction.
Skill Type: Approval and monitoring · Observable Output or Result: Greenwashing, misleading-impression and approval review
G.7-B01
Does not approve a claim because it is commercially valuable, widely used by peers or technically true in a narrow sense if the overall impression is misleading.
Behaviour Type: Claim integrity · Non-compensable Requirement: No
G.7-B02
Does not omit material limitations, trade-offs or adverse performance necessary to understand the claim fairly.
Behaviour Type: Adverse-information visibility · Non-compensable Requirement: No
G.7-B03
Does not extend assurance, certification, rating, target or specialist conclusions beyond their actual scope, criteria, period and provider.
Behaviour Type: Boundary and authority discipline · Non-compensable Requirement: No
Typical tasks · 4
G.7-T01
Inventory explicit and implied claims across the reporting package, website, investor materials, ratings submissions and related visuals.
Primary Output Link: G.7-O01
G.7-T02
Assess evidence, criteria, boundary, period, comparator, methodology, dependencies, exclusions and overall impression.
Primary Output Link: G.7-O02
G.7-T03
Identify greenwashing mechanisms and prepare qualification, revision, rejection or escalation recommendations.
Primary Output Link: G.7-O03
G.7-T04
Obtain owner, specialist, legal and governance approval and maintain expiry, reuse, change and correction monitoring.
Primary Output Link: G.7-O03
Expected outputs · 3
Level 1 · Foundation
G.7-L1-01
Can identify common sustainability claims, complete an established substantiation checklist and flag missing evidence, scope or qualification.
Indicator Dimension: Task execution
G.7-L1-02
Can recognise obvious vague, comparative, future, assurance or imagery-based greenwashing risks and escalate them.
Indicator Dimension: Quality, judgement and accountability
Level 2 · Practitioner
G.7-L2-01
Can independently review and document substantiation for a moderately complex portfolio of reporting and market-facing claims.
Indicator Dimension: Task execution
G.7-L2-02
Can assess overall impression, resolve routine scope and qualification issues and recommend supported wording, revision or rejection to management.
Indicator Dimension: Quality, judgement and accountability
Level 3 · Advanced Practitioner
G.7-L3-01
Can design or critically review enterprise claim-substantiation and greenwashing-risk methods across products, topics, reports and channels.
Indicator Dimension: Method design and review
G.7-L3-02
Can challenge commercially sensitive or legally risky claims, resolve major evidence and impression disputes and advise governance bodies on rejection, correction and public-trust risk.
Indicator Dimension: Leadership and governance
Illustrative evidence · 6
G.7-E01
Sustainability claims register and classification across text, metrics and visuals.
Evidence Type: Work product
G.7-E02
Claim substantiation and qualification file with evidence, criteria and boundaries.
Evidence Type: Work product
G.7-E03
Greenwashing, misleading-impression and approval review.
Evidence Type: Work product
G.7-E04
Claim, evidence, comparator, legal-review, revision, approval and monitoring trail.
Evidence Type: Process evidence
G.7-E05
Documented legal, marketing, specialist, assurance, quality or management review and the practitioner's response.
Evidence Type: Review evidence
G.7-E06
Observed challenge, revision or rejection of a contested sustainability claim.
Evidence Type: Observed performance
Assessment · 3
G.7-A-L1
Claim-classification exercise, substantiation checklist and situational judgement
Claim recognition; evidence and boundary; overall-impression awareness; qualification and escalation.
G.7-A-L2
Integrated greenwashing-risk case and professional memorandum
Substantiation; overall impression; qualification and adverse-information balance; legal and governance escalation.
G.7-A-L3
Complex public-claims case, portfolio and oral defence
Method design; impression and evidence judgement; assurance and certification boundaries; governance advice and oral defence.
| From | To | Type | Rationale |
|---|---|---|---|
| A.8 | G.7 | Strong linkage | Claim supportability and wording must be tested for substantiation and greenwashing risk. |
| E.3 | G.7 | Disclosure, claims and publication linkage | Target, achievement and alignment claims require support from the controlled target protocol and evidence. |
| F.3 | G.7 | Disclosure, claims and publication linkage | Public claims should not exceed the evidence available and should reflect material limitations. |
| G.2 | G.7 | Disclosure, claims and publication linkage | Achievement, alignment and trajectory claims require target evidence and qualification. |
| G.6 | G.7 | Disclosure, claims and publication linkage | Draft wording should be assessed for explicit and implied sustainability claims. |
| G.7 | A.8 | Disclosure, claims and publication linkage | Claim substantiation should align with the controlled reporting basis, criteria and approval process. |
| G.7 | F.3 | Evidence and traceability linkage | Claims require relevant, reliable and sufficiently complete evidence. |
| G.7 | F.9 | Boundary distinction | Assurance, verification, certification and accreditation claims must remain within the actual service and scope. |
| G.7 | G.8 | Disclosure, claims and publication linkage | Claims should be consistent across reporting, investor, ratings and marketing channels. |
| G.7 | G.11 | Change and lifecycle linkage | Approved claims require post-publication monitoring, expiry and correction controls. |
| G.9 | G.7 | Disclosure, claims and publication linkage | Claims should reflect material uncertainty, limitations, dependencies and omissions. |
| H.1 | G.7 | Disclosure, claims and publication linkage | Professional integrity requires claims and overall impressions not to exceed the evidence. |
| I.6 | G.7 | Disclosure, claims and publication linkage | AI-assisted claims should not enter reporting unless evidence, scope, qualification and overall impression are verified. |
| Role | Target level | Relevance | Evidence expectation |
|---|---|---|---|
| Corporate Sustainability Reporting Practitioner | Practitioner | Required? | A case or work sample demonstrating independent performance, documented judgement and a reviewable professional output. |
| Sustainability Reporting Manager or Lead | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating method design, challenge and governance capability. |
| Sustainability Reporting Adviser or Consultant | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating method design, challenge and governance capability. |
| Sustainability Data, Systems and Controls Specialist | Foundation | Supporting? | A supervised or defined work sample showing correct application, traceability and recognition of escalation needs. |
| Assurance Readiness and Reporting Quality Specialist | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating method design, challenge and governance capability. |
| Investor, Capital Markets and Ratings Disclosure Specialist | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating method design, challenge and governance capability. |