Greenwashing self-regulation: SIA focuses on implementation and audit concept

The SIA’s greenwashing self-regulation, drawn up in 2024, sets a binding minimum standard for unit-linked life-insurance policies with a sustainability focus. It is intended to ensure that statements regarding sustainability are clearly defined, substantiated and accurate. This will enable the industry to enhance transparency with regard to sustainable insurance products and boost customer confidence.

Going forward, the focus will now be on putting the guidelines into practice. Work is also being done to develop an audit concept to support uniform, verifiable implementation in practical terms. The aim is to ensure that the self-regulation is binding in practice as well as to establish a common framework for future audits. The audit concept is expected to be finalised in autumn 2026, with initial implementation scheduled for 2027.

Sandra Kurmann, Divisional Head of General Operating Conditions at the SIA, explains how the implementation is progressing and why the audit concept has a key role to play:

Sandra, what does the SIA actually mean by ‘greenwashing’?

Greenwashing means presenting products or services as more sustainable than they actually are. This is a particularly thorny issue in the financial sector, as sustainability is not always something customers can assess at first glance. This makes clear definitions, transparent criteria and straightforward communication all the more important.

What role does the self-regulation play in all this?

Statements regarding sustainability are only credible if it’s clear exactly what companies mean by ‘sustainable’. Substantiated criteria and a binding minimum standard are particularly important when it comes to sustainability-related products. And that’s exactly what this self-regulation gives us. It ensures that customers can rely on the information they’re being given.

How much progress has been made in terms of implementation?

The self-regulation has been in force since early 2025, and 13 insurance companies, representing more than 95 per cent of the market, have voluntarily signed up to it. Since then, the focus has been on implementing the self-regulation in these organisations and putting the guidelines into practice. At the same time, we’re working to establish a common understanding of how compliance with the self-regulation should be monitored in the future. This is the audit concept we’re currently developing. We expect to finalise it this autumn and then begin auditing implementation for the first time in 2027.

Does auditing even matter if you’re regulating yourself anyway?

Yes, that’s exactly why it’s so important. After all, self-regulation is only credible if the rules are clear and compliance with them can be verified. This is of interest to customers, of course, but also to the companies involved. Because if you’re going to the trouble of implementing these standards, you need to know that others are going to do the same. That’s why we need a sound audit concept; it instils trust, ensures uniform implementation and demonstrates that sustainability promises are not only being made – they’re being kept. 

Is self-regulation just a precursor to state regulation?

No. Self-regulation is a conscious decision by the industry to take responsibility and set clear standards. If these standards are binding and compliance with them can be verified, you already have an effective approach in place – without adding to the regulatory burden on the companies concerned. 

Why is it taking so long to implement?

Because it’s not simply a matter of formal compliance. The requirements have to be integrated into processes, products and systems. At the same time, there needs to be a thorough technical consultation on how the audit should be structured. It’s a complex task, but it’s also essential if self-regulation is to work in practice. But we’re on the right track, and we’re right on schedule. The self-regulation must be fully implemented by the end of 2026. The audit concept will also be finalised this autumn and applied for the first time starting in 2027.