SMFSC Issues Anti-Greenwashing Guidance, Expands Sustainability Rules

Council Strengthens Oversight of Sustainability Claims in Financial Sector

The San Marino Financial Standard Council (SMFSC) has confirmed the publication of its new anti-greenwashing guidance, marking a major step toward promoting transparency and accountability in sustainable finance.
At the same time, the council has proposed an extension of its sustainability framework, aimed at creating a more robust and verifiable foundation for environmental, social, and governance (ESG) practices within the financial industry.

These measures reflect SMFSC’s growing commitment to ensuring that sustainability claims made by financial institutions are accurate, evidence-based, and not misleading to investors or the public.

Tackling Greenwashing: Clarity Over Marketing

“Greenwashing” — the practice of exaggerating or falsely representing the environmental benefits of products or investments — has become a global concern as demand for sustainable finance continues to grow.
SMFSC’s new guidance sets out clear expectations for firms making ESG-related claims, emphasizing the importance of substantiated data, transparency in methodologies, and ongoing performance verification.

The guidance warns against ambiguous language or symbolic commitments that cannot be supported by measurable evidence.

“Sustainability cannot be a marketing slogan,” an SMFSC spokesperson said.
“Our guidance makes clear that firms must demonstrate the substance behind every claim they make.”

Expanding the Sustainability Framework

In addition to confirming its anti-greenwashing rules, SMFSC has proposed broadening its existing sustainability framework to cover a wider range of financial activities.
The proposed expansion will include:

• Integration of climate risk assessment into financial reporting and corporate governance.
  
• Enhanced disclosure requirements for ESG funds and sustainable lending products.
  
• Development of a standardized taxonomy for sustainability-related investments.
  
• Voluntary self-regulatory benchmarks for ethical conduct and impact verification.
  

These proposals aim to align San Marino’s financial system with international best practices, including principles outlined by the European Union’s Sustainable Finance Disclosure Regulation (SFDR) and the Task Force on Climate-related Financial Disclosures (TCFD).

Promoting Investor Confidence and Ethical Finance

SMFSC underscored that strengthening sustainability standards is not only a matter of environmental responsibility but also a way to build long-term investor trust.
The council’s framework seeks to ensure that investors can rely on accurate information when evaluating sustainable investment opportunities, thus supporting capital flows toward genuinely impactful projects.

By combining anti-greenwashing enforcement with transparent reporting standards, SMFSC aims to position San Marino as a credible hub for ethical and sustainable finance.

Consultation and Implementation Timeline

The council confirmed that a public consultation on the proposed framework expansion will be launched in the coming months.
Financial institutions, asset managers, and sustainability experts will be invited to contribute insights on implementation timelines, data standards, and verification mechanisms.

The final version of the extended sustainability framework is expected to be adopted in early 2026, accompanied by industry workshops and guidance materials to support compliance.

A Broader Vision for Sustainable Finance

SMFSC’s anti-greenwashing guidance and sustainability framework expansion reinforce its vision of a transparent, responsible, and forward-looking financial ecosystem.
Through self-regulation and collaboration, the council aims to ensure that sustainability in finance is grounded in substance, not symbolism.

“Our role is to make sustainability real, measurable, and credible,” the SMFSC concluded.
“By holding institutions to high ethical and disclosure standards, we’re protecting investors, supporting innovation, and strengthening trust in San Marino’s financial markets.”