June 12, 2025
Climate OrdinanceWhat Swiss companies now need to know about ESG reporting, OR 964a–c, TCFD, XBRL & more
With the law on non-financial reporting based on Article 964a of the Swiss Code of Obligations (CO) and the accompanying Climate Ordinance, sustainability is no longer just a matter of conscience—it is a legal reporting obligation. In 2025, many companies in Switzerland had to disclose their climate-related risks and opportunities for the first time, covering the financial year 2024.
Swiss regulations differ from those of the European Union’s Corporate Sustainability Reporting Directive (CSRD). While the Swiss Federal Council is monitoring EU developments closely, it has suspended the current consultation on proposals to align with the CSRD—particularly due to the fast-evolving nature of the EU's current Omnibus initiative. This pause ensures Switzerland can develop regulations that are coherent with the finalized EU framework, expected no later than spring 2026.
Swiss Regulatory Requirements
The law on non-financial reporting pursuant to OR 964a is supplemented by the ordinance on climate-related reporting. This ordinance specifies the general requirements of OR 964a et seq. and constitutes an independent legal regulation with a specific focus on climate issues.
These laws have been enacted and are therefore legally binding.
An Overview of Swiss Regulation
1. CO 964a – Non-Financial Reporting
- Requires large companies in Switzerland to disclose information on environmental, social, employee-related, human rights, and anti-corruption matters.
- Goal: Transparency on non-financial risks and the impact of business activities.
- Scope: Applies to public interest entities (PIEs) with more than 500 employees and either a balance sheet total exceeding CHF 20 million or net turnover exceeding CHF 40 million.
- The report must be approved and signed by the company’s highest governing or administrative body. The board is personally liable for incomplete or inaccurate reporting. Source: fedlex.admin.ch/eli/cc/27/317_321_377/de#art_964_c
- Source: fedlex.admin.ch/eli/cc/27/317_321_377/de#part_4/tit_32/chap_6
2. Climate Reporting Ordinance
- Specifies the requirements set out in CO 964a and integrates the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).
- Requires publication in formats readable by both humans (e.g., PDF, HTML) and machines (XBRL).
- Goal: Detailed disclosure of climate risks and impacts, based on the principle of double materiality (climate’s impact on the company and vice versa).
- Scope: Applies to listed companies, banks, and insurance providers.
- Source: fedlex.admin.ch/eli/oc/2022/747/de
What companies need to do
As part of their sustainability reporting, companies must address the following key areas. These are aligned with the former TCFD recommendations and similar international frameworks like the ESRS and ISSB:
- Governance: How is climate risk integrated into corporate governance?
- Strategy: What climate-related risks and opportunities exist?
- Risk Management: How are these risks identified and managed?
- Metrics & Targets: What metrics and targets are used to measure progress?
Reporting Requirements
The ordinance does not mandate a specific reporting standard, allowing for flexibility. However, it references international frameworks such as the European Sustainability Reporting Standards (ESRS) and IFRS Sustainability Standards (ISSB). The taxonomy of the widely used GRI Standards remains open.
The climate report must be publicly available and readable by both humans and machines—ideally integrated into the sustainability report, annual report, and published on the company’s website.
Machine-Readable Reporting Requirements
Effective as of the 2025 reporting year, companies must ensure that climate reports are machine-readable.
What does “machine-readable” mean in this context?
According to Article 4, Paragraph 2 of the Climate Ordinance, reports must be published in formats readable by both humans (e.g., PDF) and machines.
Source: fedlex.admin.ch/eli/oc/2022/747/de
Specifically:
- Reports must be provided in a widely recognized electronic format.
- This format must be compatible with both human and machine reading.
- XBRL (eXtensible Business Reporting Language) is currently the only recognized format for this purpose. It enables automated processing of large data volumes and is already established for financial reporting in the EU.
- Source: eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32019R0815
When does this requirement take effect?
Applies to reporting periods starting January 1, 2025. The first machine-readable report must be published in 2026 for the financial year 2025.
Why is machine readability important?
- Automated processing: Regulators, investors, and analysts can more easily process and compare data.
- International compatibility: Switzerland aligns with global standards such as ESRS and IFRS SDS S1/S2.
- Future-proofing: Companies active in the EU are already preparing for or applying XBRL under the Transparency Directive.
How we support you
mms is a leader in ESEF XBRL implementation — mandatory in the EU since 2020 for financial reports. Our built-in tagging plus module is already trusted by 50 companies. The same technology supports XBRL compliance in ESG reporting. To reduce complexity and support your implementation, we offer:
- Webinar «mmsSpecial» on legal compliance, XBRL, machine readability, and tagging
- Technical assistance with ESG reporting systems
- Consulting, workshops, and implementation of tagging for climate reporting, regardless of the chosen standard (ESRS, ISSB, GRI)
- Templates for structured data integration
Our experts, Olivier Neidhart and Daniel Schön, are happy to answer your questions.
