Treasury’s second consultation on Sustainable Investment Product Labelling closed on 13 March 2026.

The development of a labelling regime is part of the Government’s Sustainable Finance Roadmap, with commencement targeted for 2027, and focuses on key design elements including scope, consumer-facing disclosures, labelling thresholds and evidence requirements.

ASFI’s submission expressed support for the direction of Treasury’s proposals while noting that it was important not to overstate what product labelling can achieve. 

Product labelling can strengthen confidence in the sustainable finance market and support more informed decision-making, particularly for retail investors. However it does not, on its own, drive a significant allocation of capital toward sustainable activities.

The extent to which capital shifts will depend on broader policy settings, including disclosure frameworks, taxonomy alignment, and how investment opportunities are structured and brought to market.

A well-designed regime can improve comparability and reduce the risk of misleading claims, but its effectiveness will depend on how clearly expectations are defined and how consistently they can be applied across different investment approaches.

Achieving Australia’s sustainability objectives and positioning the Australian economy for a low-carbon future will require a broader suite of policy settings. 

Summary of positions

• Supports the introduction of a sustainable investment product labelling regime  that strengthens consumer trust, comparability and market integrity, while allowing flexibility across different investment approaches

• Supports a disclosure-focused approach, applying to financial products marketed as sustainable (broadly defined)

• The regime should align with the expectations of a reasonable retail investor

• Flexibility is required to accommodate different investment approaches and strategies

• In some areas, common definitions and methodologies may be required to support comparability and reduce complexity

• Product labelling improves transparency, but does not, on its own, drive significant capital allocation toward sustainable activities

• Broader policy settings will determine whether capital is directed at the scale required