Switzerland's Climate Disclosure Rules: What You Need to Know

Switzerland's climate disclosures at a glance

The Swiss Federal Council adopted the Ordinance on Climate Disclosures on 23 November 2022 and brought it into force on 1 January 2024, requiring large listed companies, banks, and insurers to report climate matters on the four TCFD pillars, with a transition plan, quantitative CO2 targets, and greenhouse gas emissions, from the 2024 financial year.

A second phase is under way: the draft Federal Act on Sustainable Business Conduct, in consultation until 9 July 2026, would move climate disclosure into a single law with external review and thresholds aligned with the European Union.

Below: what the rules require, and how to prepare.

What Switzerland's climate disclosure rules require

In-scope companies publish a climate report inside their annual non-financial report, structured on the four TCFD pillars, with a transition plan, quantitative targets, and greenhouse gas emissions.

• Code of Obligations, Articles 964a to 964c, the legal basis. Large public interest companies report annually on environmental matters (including CO2 targets), social and employee matters, human rights, and anti-corruption, covering business model, policies, measures and their effectiveness, main risks, and key performance indicators. A company with no policy on a matter explains why (Article 964b paragraph 5).

• Ordinance on Climate Disclosures, Article 3, the climate content. A company that reports on the TCFD recommendations and the 2021 implementation guidance is presumed to have met its climate reporting duty (Article 2). The strategy pillar includes a transition plan comparable with Swiss climate goals. The metrics and targets pillar includes, where possible and appropriate, quantitative CO2 targets, disclosure of all greenhouse gas emissions, and the assumptions, methods, and standards used.

• Double materiality. Climate matters cover the effects of climate change on the company and the effects of the company's activities on climate change (Article 1 paragraph 2).

• Publication format. Electronic publication on the company's website in at least one human-readable and one machine-readable, internationally used format (Article 4), available for at least ten years (Article 964c).

The GHG Protocol as the measurement standard. The TCFD guidance the ordinance references directs companies to calculate emissions in line with the GHG Protocol Corporate Accounting and Reporting Standard (2004), the same standard IFRS S2 mandates in paragraph 29(a)(ii).

Who is in scope

Every Swiss public interest entity that meets the size test reports, with no phase-in. Article 964a of the Code of Obligations sets three tests that apply together, measured on a consolidated basis in two consecutive financial years:

• Public interest entity: a listed company, a bank, or an insurer, as defined in the Audit Oversight Act (Article 2 letter c).

• Headcount: at least 500 full-time equivalents on annual average, including controlled entities in Switzerland or abroad.

• Financial size: a balance sheet total above CHF 20 million, or revenue above CHF 40 million.

Subsidiaries and foreign issuers. A company controlled by a parent that reports under Article 964a, or that produces an equivalent report under foreign law, is exempt (Article 964a paragraph 2); the parent's report covers all controlled entities in Switzerland and abroad (Article 964b paragraph 4). SIX Exchange Regulation applies the rules to foreign issuers listed on the SIX Swiss Exchange.

Supply-chain reach (Terrascope analysis, based on the ordinance text). Disclosure of all greenhouse gas emissions, where possible and appropriate, includes Scope 3. Suppliers to Swiss-listed food, pharmaceutical, chemical, and industrial groups should expect requests for primary emissions data, whether they sit in Switzerland, Germany, Italy, France, or further along the value chain.

Note on financial institutions. Banks and insurers report under the same ordinance. The Swiss Financial Market Supervisory Authority separately requires them to manage nature-related financial risks under FINMA Circular 2026/1, in force since 1 January 2026. This page covers the corporate disclosure duty only.

Key dates and milestones

The December 2024 revision draft proposed recognising IFRS S1 and IFRS S2 or the European Sustainability Reporting Standards as accepted frameworks alongside minimum requirements for net-zero transition plans. The Federal Council paused that revision on 25 June 2025 until the Code of Obligations is amended; the April 2026 draft Federal Act is the next step it announced.

What is changing: the draft Federal Act on Sustainable Business Conduct

The Federal Council opened consultation on 2 April 2026 on a Federal Act on Sustainable Business Conduct, its indirect counter-proposal to the popular initiative on responsible business. Everything in this section is subject to consultation.

• Scope narrows. In the Federal Council's own estimate, around 100 companies would report under the new law, compared with the 200 that report today, so that Swiss thresholds match the EU's rules after the Omnibus simplification.

• External review becomes mandatory. Companies in scope would have their sustainability report reviewed by an external audit firm.

• One law, one supervisor. The draft brings the reporting duty into a single act with a national supervisory authority; the Federal Council proposes the Federal Audit Oversight Authority for that role.

• Timing. Consultation closed on 9 July 2026. The Federal Council's dispatch to Parliament and the entry-into-force date are not yet published.

Until the new law takes effect, the Ordinance on Climate Disclosures and Articles 964a to 964c remain the rule.

Why this matters beyond Switzerland

1. Supply-chain ripple across Europe. Swiss-listed groups in food, pharmaceuticals, chemicals, machinery, and luxury goods source across the EU, Asia, and the Americas. A transition plan comparable with Swiss climate goals and disclosure of all greenhouse gas emissions turn those suppliers into data sources.

2. Regulatory convergence. Switzerland is moving from a TCFD basis to the standards its neighbours use: the proposed revision recognises IFRS S2 and the ESRS, and the draft Federal Act matches EU thresholds after Omnibus. Companies already reporting under the ISSB standards or the EU rules can reuse most of that work.

3. Jurisdictional precedent. Switzerland wrote a transition-plan requirement into binding law early. Adding external review and a supervisory authority signals where comparable regimes, including Australia and Singapore, are heading: from disclosure to verified disclosure.

How companies should prepare

• Establish your GHG inventory. Scope 1, Scope 2, and Scope 3 measured under the GHG Protocol Corporate Accounting and Reporting Standard (2004), with assumptions, methods, and standards documented, because the ordinance asks for exactly that disclosure.

• Build assurance-ready processes early. The draft Federal Act proposes external review of the sustainability report. Every figure needs a source, a method, and a reviewer before an audit firm asks for them.

• Build on the frameworks you already use. A TCFD report maps directly onto IFRS S2's four pillars, and a CSRD-aligned report covers ESRS E1. Reuse the governance, risk, and metrics content you already have.

How Terrascope can help

Terrascope's AI-powered platform helps companies operating in Switzerland move from baseline emissions data to audit-ready disclosures, including Tectus Group, the Zurich-headquartered building technology group that used the platform to find the emission hotspots in its products and redesign building materials with lower embodied carbon.

• Scope 1, 2, and 3 emissions measurement. Integrations pull activity data from ERP, procurement, and utility systems monthly, so the "all greenhouse gas emissions" line in your report comes from source data.

• Audit-ready reporting. Audit Trail records every data entry, emission factor, and method change, and gives your reviewer direct access to the evidence, so "where did this number come from?" is answered in the platform.

• Supply-chain intelligence. Analytics shows which suppliers, products, and sites drive Scope 3, so the transition plan rests on measured numbers.

• Multi-framework alignment. ISSB Reporting drafts the four-pillar disclosure once and maps it to TCFD, IFRS S2, and ESRS E1, so a change in Switzerland's accepted standard means a remap of existing content.

Frequently asked questions

Speak to an expert

Are you ready to get ahead of Switzerland's climate disclosure requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.