Navigating the AMAS self-regulation 2.2: How to avoid greenwashing for sustainable collective assets?

Switzerland is a leading centre for sustainable finance, with a growing number of asset managers and institutional investors, and regulatory and market initiatives supporting responsible investment. Over the past year, the country has seen significant inflows into Swiss sustainable investment products which reached a total volume of CHF 1,881 billion in 2024¹, reflecting increasing investor demand for solutions that align with environmental and social values.

Swiss investors, including pension funds and private wealth clients, are seeking more credible sustainable investment options, prompting asset managers to enhance transparency and impact measurement.

The AMAS self-regulation 2.2 complements other ongoing Swiss initiatives and existing regulations and guidance such as FINMA’s guidance on greenwashing risk and the efforts of Swiss Sustainable Finance (SSF) to align market practices and promote best practices for sustainable investing.

Together, these developments create an environment where sustainable finance is a market opportunity and also carries a responsibility to deliver genuine sustainability outcomes. Asset managers who follow the AMAS self-regulation 2.2 guidelines position themselves competitively by meeting the expectations of Swiss investors and regulators.

¹ Swiss sustainable market study 2025, SSF

What do you need to know about the AMAS self-regulation 2.2?

The AMAS self-regulation 2.2 adopts a principles-based approach and provides a set of principles and requirements aimed at standardising the way sustainability is integrated and communicated in collective investment schemes that are marketed as sustainable. It recognises the increasing demand from investors for transparency and credibility in sustainable investment products and aims to promote the reputation of Switzerland as a centre for sustainable finance. This self-regulation applies to active AMAS members which either manage sustainability-related collective assets in Switzerland ("asset managers") or operate Swiss sustainability-related collective investment schemes ("producers"). The self-regulation 2.2 defines clear criteria for what qualifies as a sustainable collective investment scheme and requires producers and asset managers to substantiate sustainability claims with robust methodologies and documented internal processes. It also emphasises the importance of transparency in disclosing how sustainability considerations are integrated into investment decisions.

The AMAS self-regulation 2.2 sets a framework that promotes consistency, credibility, and investor protection, and it aligns with broader international efforts to avoid greenwashing and ensure that sustainability claims are meaningful and verifiable.

The self-regulation 2.2 also introduces a requirement to have independent assurance performed to attest that the implemented framework and processes are in alignment with the self-regulation. This independent assurance must be performed by an independent state-regulated audit firm and must be based on the audit programme drawn up by AMAS.

The principles of the self-regulation 2.2 are applicable to AMAS members and cover both institution level (1) and product level (2) requirements applicable to:

• producers of collective investment schemes marketed as sustainable
• asset managers of collective investment schemes marketed as sustainable

What does this mean for you?

The AMAS self-regulation 2.2 requires asset managers and producer of collective investment schemes to have a credible sustainable investment policy and defined sustainable objectives for the funds, and to apply the sustainability approaches defined by AMAS. Below is an overview of approaches typically accepted and not accepted in order to consider a collective investment scheme as sustainable² .

Vague or unsupported sustainability claims, superficial ESG integration, adoption of exclusions alone or with other “weak” approaches as well as marketing without substantiated evidence are not consistent with the principles set out in the self-regulation and expose you to the risks of mis-selling and greenwashing.

In order to comply with the self-regulation 2.2, asset managers or producer of collective investment schemes are required to maintain comprehensive documentation of their sustainability classification methodologies and approaches, sustainability frameworks, data sources (including appropriate due diligence for third-party data providers), processes and governance structures. Regular monitoring and transparent reporting are also essential to uphold credibility in the longer term.

How ready are you for the AMAS self-regulation 2.2?

• Have you established clear sustainability objectives and policies for your funds?
• Are your sustainable investment approaches and processes appropriately documented and with the right level of detail?
• Do you regularly monitor and report on sustainability progress of your funds against their objectives?
• Do your fund documentation (both pre-contractual and periodic) and marketing materials accurately reflect the sustainability objective, approach and sustainability profile of the fund?
   

Conclusion

As Switzerland’s sustainable finance sector matures, the expectations placed on asset managers and producers of collective investment schemes are becoming significantly more rigorous. Today, the market and regulators demand genuine substance - requiring not only well-defined sustainability objectives but also robust methodologies, transparent processes, and comprehensive documentation.

For industry participants, this presents both a challenge and an opportunity. Starting from March 2026, the challenge lies in developing and maintaining appropriate internal frameworks, governance structures, and data-driven processes needed to substantiate every sustainability claim and in obtaining external assurance over them. However, those who rise to this challenge and equip themselves to meet the requirements will benefit from lower compliance costs, reduced reputational risks, enhanced credibility, stronger client relationships, and a competitive edge in a rapidly expanding market.

Authors

• Christian Jung, Director, Sustainable Finance Lead
• Christian Weber, Director, Asset Management
• Claire Ledrich, Senior Manager, Sustainable Finance, Internal Control
• Greta Cenotti, Manager, Sustainable Finance