Across Australia and New Zealand, Environmental, Social and Governance (ESG) credibility has fused with compliance credibility.
For boards, compliance leaders, risk officers and legal teams, the two are no longer separate disciplines but one mandate: prove control.
The regulators have drawn the line.
The Australian Securities and Investments Commission (ASIC) and New Zealand’s Financial Markets Authority (FMA) have put greenwashing at the centre of their enforcement priorities.
For banks, this is the new boundary between resilience and risk. Any ESG statement - in a disclosure, a product launch, or a third-party contract - that cannot be backed by live, verifiable evidence risks falling into the category of greenwashing, and with it, the scrutiny of investigation.
ESG Compliance Is the New Measure of Trust
For banks across Australia and New Zealand, greenwashing is now much more than just a reputational risk.
- ASIC has placed misleading ESG statements at the centre of its enforcement priorities, with greenwashing explicitly listed as a top focus. In March 2025, ASIC fined Active Super A$10.5 million for misleading ESG claims, one of the largest penalties of its kind.
- In December 2024, the FMA publicly censured Pathfinder for overstating fossil fuel exclusions in its funds - a clear signal that scrutiny is intensifying. Non-compliance can range from public rebuke to substantial financial penalties.
The message from both regulators is unequivocal: intentions and marketing claims are irrelevant unless backed by hard, verifiable evidence. ESG credibility is now inseparable from regulatory compliance, customer trust and long-term resilience.
The Real Risk of Weak ESG Compliance Controls
For many banks, ESG due diligence is still fragmented across spreadsheets, questionnaires and attestations, and even business functions. These piecemeal approaches create a false sense of control, leaving banks exposed just when regulators are demanding hard evidence.
With regulators no longer satisfied by policies or good intentions, bank boards shouldn’t be either. The risks are clear:
- False confidence: Boards may believe their bank has ESG covered, but unsuitable processes leave them exposed to regulatory sanction and reputational damage
- Failure under scrutiny: ASIC and FMA now demand verifiable, current evidence. Incomplete or inconsistent processes fail these tests just as much as inaction
- Wasted resources: Compliance teams spend hours chasing data across teams and systems, yet the results rarely meet regulators expectations.
ESG half-measures are not a safe compromise. They are active liabilities. They drain resources, create blind spots, and invite regulator scrutiny.
To preserve credibility with regulators, boards and customers alike, every ESG claim must be underpinned by live, auditable evidence that demonstrates control in practice, not just policy.
The question is no longer whether to strengthen ESG compliance, but how quickly banks can implement systems that regulators will accept as proof.
Why Banks Trust Gatekeeper to Deliver ESG Compliance Evidence
Embedding ESG assurance into banking compliance is where Gatekeeper, powered by LuminIQ AI agents, delivers measurable impact.
As the only unified platform for contracting, third-party and spend management, Gatekeeper connects ESG obligations directly to contracts and vendor due diligence, while LuminIQ automates the compliance grind by capturing attestations and surfacing risks so you can take preventative action.
The result is clarity, control and credibility: banks can move from fragmented, manual approaches to a single, auditable framework that stands up to regulatory scrutiny.
Here’s how Gatekeeper transforms today’s ESG compliance pressures into tangible results for banks:
| Challenge |
Outcome with Gatekeeper |
| ESG goals and questionnaires are often built from scratch: this leads to inconsistency and slow adoption. |
Pre-built ESG best-practice workflows and compliance-ready questionnaires give banks a head start, ensuring standards are defined consistently and applied immediately across the supply chain. |
| ESG clauses often lack enforcement: Even when included in contracts, ESG commitments are rarely monitored, leaving obligations unenforced |
Continuous monitoring embeds right-to-audit clauses and automated alerts, ensuring that ESG obligations remain active throughout the contract lifecycle |
| ESG definitions and exclusions vary across teams: Without consistency, criteria are applied unevenly, creating gaps regulators can exploit |
A single policy engine captures ESG definitions, exclusions and controls, ensuring they are applied consistently across vendors, suppliers, and investment products |
| ESG evidence is inconsistent across the bank: Different business units capture ESG data in different ways, leaving compliance teams with gaps and conflicting information |
All ESG answers, attestations and approvals are captured in one policy-driven workflow and tied to contracts. The LuminIQ ESG Assessment Reviewer checks incoming responses against internal ESG standards, automatically creating a single, trusted record regulators accept. |
| ESG risks slip through at onboarding: Without systematic checks, high-risk vendors and investment products enter the bank’s ecosystem undetected, exposing institutions to regulator penalties |
Risk-first vendor onboarding applies ESG criteria up front, blocking non-compliant third parties before they enter the supply chain or portfolio. LuminIQ accelerates this process by instantly flagging high-risk vendors before contracts are signed. |
| Regulators demand an auditable trail: ASIC and the FMA no longer accept policies or good intentions, they require verifiable proof at a moment’s notice |
Every contract, attestation, and ESG commitment is linked in a single, audit-ready record, available instantly for regulator or board review |
For banks across Australia and New Zealand, the value goes beyond efficiency. It removes the blind spots that turn ESG claims into greenwashing risks by unifying contracts, vendor attestations, and policy enforcement into one auditable framework.
Conclusion
Banks across Australia and New Zealand now face a decisive moment. ASIC and FMA have made it clear: ESG credibility must be proven with evidence, not asserted with intention.Institutions that persist with fragmented ESG processes will face rising penalties, reputational damage and loss of stakeholder trust. Those that embed evidence-led assurance satisfy regulators while strengthening resilience, governance and long-term credibility in the eyes of customers and investors.
Gatekeeper provides the only unified platform that makes this shift possible, linking contracts, vendor due diligence and ESG oversight into a continuous, audit-ready framework. With LuminIQ automating the evidence collection and monitoring, ESG becomes a discipline that boards can stand behind with confidence.
Book a demo to see Gatekeeper’s ESG Best-Practice Workflow in action, and discover how your ESG claims can withstand ASIC and FMA scrutiny with confidence.
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