Chartered Accountants Australia and New Zealand (CA ANZ) is pleased to have jointly submitted our feedback to Treasury’s consultation on sustainable investment product labels. This submission reflects our commitment to supporting a financial system that is transparent, consistent, and accountable particularly in the superannuation sector.

We strongly support the development of a labelling framework that enhances clarity, comparability, and integrity in sustainability claims. Our position is grounded in previous work, including submissions faith-based product benchmarking and the Annual Superannuation Performance Test.

We believe that investor-facing terminology such as “growth,” “balanced,” or “conservative” must be uniformly defined across the investment landscape. This is especially important for superannuation funds, which are among the largest stakeholders impacted by this framework. We recommend a hybrid model where core approaches are prescribed in legislation, but allow industry to propose new ones subject to regulator approval. It may be that prescription is better left to regulatory instruments and guidance to allow for evolution product offerings. This would mean legislation should be at a higher level.

We also emphasise the need for regulatory oversight to prevent greenwashing, greenhushing, and regulatory arbitrage. Our goal is to empower retail investors to make informed decisions and to ensure that superannuation products are held to high standards of transparency and accountability.