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RIAA supports the principle-based approach adopted in the Proposed guidance for ethical investing disclosure (proposed guidance) and recognises its potential to strengthen market practices, reduce the risk of greenwashing, and build trust across the financial system. As demand for responsible investment continues to grow, clear and consistent disclosure expectations are essential to ensure that product issuers can confidently communicate their strategies, and that retail investors can make informed decisions aligned with their values, goals, and risk preferences. When implemented effectively, this guidance can help foster a more inclusive and credible responsible investment market – one that reflects the diversity of consumer and retail investor motivations and supports the transition to a sustainable economy.
In addition to responding to the specific consultation questions, RIAA has recommended the FMA aligns the final guidance with RIAA’s Responsible Investment Standard. In the absence of specific legislation or regulatory guidance, RIAA established the Responsible Investment Certification Program two decades ago with the aim of improving the products which are offered to consumers and retail investors and to raise industry standards. As at October 2025, over 350 financial products are certified under this program. As Australasia’s leading expert and standard-setter on sustainable financial product labelling, RIAA brings over 25 years of expertise to this consultation.
Aligning the FMA’s final guidance with the Responsible Investment Standard represents the most efficient and effective pathway to achieving international interoperability. By doing so, the FMA has an opportunity to provide greater clarity for product issuers, avoid duplication, contribute to strengthening disclosures for product issues and consumers, and ensure that New Zealand remains in step with global best practice.
RIAA would welcome the opportunity to further support the FMA in refining this guidance, including through convening a workshop or roundtable with our members. We thank those RIAA members who contributed to the development of this response.
Summary of recommendations
• Ensure international alignment and interoperability of the final guidance.
• Reference and endorse the market standard in New Zealand being RIAA Certification and the Responsible Investment Standard.
• Reflect global practice by moving from the term ‘ethical’ from the proposed guidance to using terms such as ‘sustainable or similar’ or also adopt ‘sustainability-related’ to describe the financial products in the proposed guidance.
• Clarify that ethical or sustainability-related products may appeal to investors for a range of reasons, – including financial performance, risk mitigation, thematic exposure, or alignment with broader sustainability goals – not solely personal “ethical values”.
• Reflect industry practice and amend the description of how investment strategies are used within the responsible investment industry, and ‘impact’ investing.
• Define specific terms used in the proposed guidance such as “vanilla financial product” and “issuer” to ensure the proposed guidance is a self-contained resource.
• Clarify how the proposed guidance interacts with existing portfolio holdings disclosure requirements, particularly in relation relating to screens.
• Acknowledge the role of climate-related disclosure, including voluntary reporting by product issuers.
• Revise and amend the overly narrow focus on voting rights and shareholdings within active ownership and the description of stewardship.
• Provide additional guidance on product labelling, referring to the four key concepts of information about financial products.
• Review the current regulatory framework for third party data providers and consider providing guidance and setting minimum expectations for this sector to mitigate risks to issuers.
• Expand and refine examples in the proposed guidance to ensure they are proportionate to the scope of products and issuers covered and reflect the full spectrum of responsible investment strategies in use across the market. Detailed comments in Appendix A of the submission.
General comments
Recognise and reflect the importance of international alignment
RIAA strongly recommends that the final guidance explicitly acknowledge the importance of international alignment and interoperability with global responsible investment frameworks. As financial markets become increasingly interconnected, ensuring that New Zealand’s regulatory settings are compatible with international practice is essential for maintaining market integrity, reducing compliance burdens, and enabling cost-effective operations for global issuers.
For product issuers and platforms operating across jurisdictions, regulatory fragmentation can create significant barriers to entry, increase administrative complexity, and hinder the scalability of sustainable finance offerings. Conversely, alignment with globally accepted standards and definitions facilitates smoother cross-border distribution, enhances investor confidence, and supports the development of a robust and competitive responsible investment market in Aotearoa New Zealand.
Align the final guidance with RIAA’s Responsible Investment Standard
RIAA strongly encourages the FMA to endorse and encourage issuers to align with the RIAA Responsible Investment Standard (RI Standard), the longest running certification of responsible investment products in the world. The Responsible Investment Standard is informed by 25 years of RIAA’s experience in being the foremost authority on responsible investment in Australasia. The Standard has been supported by market defining research, RIAA’s 500+ members’ deep market knowledge, and regulatory guidance.
Our Responsible Investment Standard and Certification Program are already recognised and utilised by issuers operating across multiple jurisdictions. RIAA Certified product providers have consistently demonstrated that adherence to the Responsible Investment Standard enables them to meet the expectations of regulators and investors in both domestic and international markets.
Specifically, RIAA’s membership, as well the assets under management of certified products in New Zealand, already encapsulates a significant proportion of the New Zealand financial market, effectively setting the benchmark for responsible investment:
• Certified NZ products account for NZD101.5 billion of assets under management which is 43.5% of the comparative NZ retail market (ISS PFL as at June 25).
• 9 out of the 10 largest KiwiSaver investment products by members are products certified by RIAA.
• There are currently 241 certified products available for investment in NZ market across 44 product providers. (Data based on October 2025 Certified Product List).
Accordingly, we submit that aligning the FMA’s final guidance with the Responsible Investment Standard represents the most efficient and effective pathway to achieving international interoperability. This approach would not only reduce duplication and regulatory friction for issuers but also ensure that New Zealand remains in step with global best practice.
In support, we have made specific recommendations throughout this submission, including revisions to the terminology used in the proposed guidance and guidance on product labelling (see response to Question 5).
