On January 26, ISDA submitted a response to the UK Financial Conduct Authority’s consultation on GC23/3: Guidance on the Anti-Greenwashing Rule. In the response, ISDA highlights that actual or perceived misrepresentation of sustainability features may have a detrimental impact on investor and consumer perceptions of sustainable finance products, and ISDA supports efforts to enhance trust in the market. ISDA considers that sustainability-linked derivatives, environmental, social and governance derivatives and voluntary carbon credits fall within the scope of the rule. ISDA also notes that, as drafted, the guidance – and examples therein – is heavily retail focused. It would be helpful to ISDA members for future guidance to include a wholesale focus, with examples relevant to the over-the-counter derivatives market.