Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Fintech and Canada’s Updated Rules for Environmental Claims
Greeneashing Rules | Nov 24, 2025
Canada Updates Greenwashing Rules and What Fintechs Need To Know
On November 18 2025 the federal government introduced proposed changes to Canada’s environmental claim and greenwashing rules through Bill C-15, building on the November 4 2025 federal Budget. These proposals respond to concerns from businesses that the original 2024 framework increased uncertainty and cost. For financial technology firms that use climate related data or sustainability linked claims, these adjustments have important implications.
What The Original Regime Introduced
The original greenwashing provisions came into force through Bill C-59, which received royal assent on June 20 2024. See NCFA's fintech focused overview of the original green claim rules.
When the Competition Bureau released the June 2025 environmental claims guidance, firms received clearer detail on what regulators expected for forward looking climate statements, evidence standards and internal documentation. Even with that guidance, companies found the requirements strict and often unclear, particularly around which international standards qualified.
Why and What Changes Under Bill C-15
Bill C-15 proposes to adjust parts of the greenwashing rules that came into force in 2024. The government introduced these changes because many companies, including financial institutions, said the original rules were too unclear and made it difficult to speak openly about their environmental plans.
Bill C-15 responds to those concerns by removing the requirement that business level environmental claims must follow an internationally recognized methodology, which was one of the main sources of confusion. Businesses would still need evidence to support any environmental claim they make but they can focus on internal logic and documented methods.
See: Rising AI Energy Use: A Call for Sustainable Innovation
Bill C-15 also proposes to change how greenwashing complaints are handled. Under the rules introduced in 2024, private parties such as advocacy groups, competitors or individuals can file applications directly with the Competition Tribunal for business environmental claims. This direct access was part of broader competition law reforms and became a significant concern for companies. Bill C-15 would remove that direct pathway and require private parties to bring their concerns to the Competition Bureau instead. The Bureau would then decide whether a case should proceed. The government introduced this change because many firms said the threat of direct Tribunal applications increased uncertainty and could discourage them from sharing legitimate climate related information.
The proposed changes aims to preserve protections against misleading claims while reducing the risk of unnecessary or strategic litigation.
Comparison Before and After the Changes
| Consideration | Original 2024 Rules | Updated 2025 Rules (Bill C-15) | What This Means For Fintechs |
| How Environmental Claims Are Justified | Required adequate testing and alignment with an internationally recognized methodology | Requires substantiation but allows firms to use documented internal methods | More flexibility in climate data modelling, ESG scoring and analytics tools |
| Interpretation Burden | High. Firms struggled to interpret which global frameworks counted | Lower. Evidence judged on internal consistency | Clearer expectations reduce risk of misinterpretation |
| Documentation Expectations | Documentation needed to show alignment with international frameworks | Firms must document data sources and assumptions but no external alignment is required | Focus on internal logic and auditability |
| Future Oriented Climate Claims | Long term claims required alignment to global pathways | Claims still require evidence but internal pathways may be used | Forecasts need realistic milestones rather than matching global models |
| Risk of Challenge | Higher due to methodology disputes | Lower for methodology disputes but misleading advertising rules still apply | Risk shifts toward evidence quality |
| Enforcement Pathway | Private parties could bring cases to the Tribunal | Complaints routed through the Competition Bureau | Fewer activist driven cases but oversight continues |
| Practical Impact on Companies | Some firms paused climate commitments due to uncertainty | More predictable expectations support climate initiatives | More predictable environment for climate product development |
| Compliance Costs | Higher due to ambiguity around methodology | Moderate. Costs remain but ambiguity decreases | Less need for external validation. More need for strong internal controls |
| Innovation and Competitiveness | Rigid framework slowed innovation | Flexible system encourages innovation | Fintechs gain room to differentiate through credibility |
| Investor Signal | Uncertainty signalled regulatory volatility | Clear expectations reduce perceived friction | Fintechs become more attractive to investors |
Fintech Implications
Claim Support And Data Systems
Fintech firms need strong and reliable data infrastructure to support any environmental claims made in their products or services. While the updated rules remove the pressure to match a specific international framework, but they do not lower the expectation for clear evidence. Fintechs must be able to show how their data is collected, how their models work and why their outputs are reasonable.
See: Green Fintech 2.0 Shows Progress in the UK
Internal logic, consistency and transparent documentation matter more than ever because the assessment standard focuses on whether a claim can be substantiated using the firm’s own methods. This means the credibility of a fintech product depends heavily on the quality of its data foundations and (environmental) claims.
Future Climate Commitments Also Carry Risk
Any statement about future emissions, climate pathways or long term environmental outcomes requires realistic modelling and measurable steps.
This risk was highlighted when the Royal Bank of Canada pulled back its sustainable finance commitment after saying it could not confidently measure progress under the current rules.
Fintech tools that produce projections, risk curves or carbon estimates must demonstrate how the assumptions behind those outputs were chosen and how progress will be tracked. Future oriented claims remain high risk unless methods, milestones and supporting records are clear.
Compliance Costs And Competitive Positioning
The updated framework may reduce the cost that came from interpreting international standards, but meaningful compliance work remains. Fintechs still need controlled data environments, version tracking, testing protocols and maintained audit trails.
Read: Sustainability: A Must for Fintech Growth
Firms that use verification as a core part of product design can position themselves ahead of competitors because customers and investors will expect transparency in climate related data. Strong internal controls also help firms defend claims if they are questioned by regulators or partners.
Risk Remains, Gatekeeper Pathway Changes
Removing direct access to the Competition Tribunal lowers the chance of activist driven cases, but environmental claims will continue to be reviewed under misleading advertising rules.
The Competition Bureau remains the main decision maker and it can act where evidence is weak or claims are overstated. For fintechs this means that scrutiny continues but will be more predictable and clearer process. Firms should expect oversight to focus on accuracy and evidence rather than whether a specific global methodology was used.
Priorities For Fintechs Right Now
Fintech teams should review the environmental claims used in products, marketing or investor materials and ensure the evidence behind those claims is complete and easy to explain.
Internal methodologies should be clear so product, compliance and technical teams can show how calculations and scores are produced. Future oriented statements need documented assumptions, milestones and data sources.
See: AI Energy Score Ratings A Step Towards Transparency in AI
Firms should also monitor the progress of Bill C-15 and upcoming Competition Bureau guidance so they can adjust their documentation and product practices as expectations evolve.
Why This Matters
Environmental credibility impacts how investors and partners evaluate opportunities in sustainable finance and climate technology ventures. The updated rules aim to keep protections against misleading claims while reducing uncertainty that can slow down innovation. Fintechs that build strong and transparent verification systems can strengthen their competitive position, support customer confidence and contribute to a more trusted and transparent sustainable finance ecosystem in Canada.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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