In Responsible Investment, the language of sustainability is prevalent. That said, not all claims are created equal. From 2020 to 2024, the RIAA Certification Program increasingly focused on how products substantiate their sustainability-related disclosures (see: Assessment Note – Products trading with ‘sustainable’ in the product label), particularly those referencing the Sustainable Development Goals (SDGs).
11.4% (AU) and 19% (NZ) of all required product uplifts during certification were tied to sustainability claims. These conditions addressed two distinct areas: positioning on broad sustainability objectives and specific claims of SDG-alignment.
Table 1: RIAA Certification Program trends – sustainability claims conditions by year
Sustainability claims refer to statements about positive environmental and social positioning, for example, “sustainable investing” or “positive tilt.” During certification, these claims were at times found to lack clear definitions or metrics.
SDG-alignment claims are a subset of sustainability claims that go further, asserting that a product’s holdings align to specific UN Sustainable Development Goals. These require a defined methodology, evidence of SDG-related metrics, and clarity on how holdings are mapped to goals.
The Program found that some products used SDG icons or language without substantiating how their investments were meaningfully linked to those goals. One fund claimed that over 80% of its assets aligned with the SDGs but failed to benchmark this against a market index or disclose its mapping methodology. Another used SDG references in its factsheet but offered no supporting data.
Product changes required
Products seeking certification were required to:
- Demonstrate intentional processes and practices
- Disclose methodologies for SDG mapping
- Clarify how adverse effects were identified and mitigated
- Provide evidence of consideration of net effects in claims made
The Program required issuers to revise disclosures, benchmark claims, and remove SDG references where substantiation was lacking.
Table 2: RIAA Certification Program trends – breakdown of sustainability claims conditions by product type
Country nuances
New Zealand products, particularly KiwiSaver, were more likely to reference SDGs and sustainability-themed frameworks. They also faced conditions requiring clearer methodologies and disclosures. Australian superannuation and managed funds were flagged for broad sustainability claims lacking substantiation.
Why this matters
Responsible Investment is not a function of icons or slogans. Clarity, consistency, and credibility are essential. Investors deserve to know how their money is aligned with their sustainability priorities. RIAA’s Certification Program ensures that both broad sustainability claims and SDG-alignment references are measurable and transparent.
As demand for responsible investment increases, expectations of product accountability will too. Certification is drawing the line between gloss and substance and holding the market to it.
