June 12, 2025
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.
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.
1. CO 964a – Non-Financial Reporting
2. Climate Reporting Ordinance
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:
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.
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:
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?
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:
Our experts, Olivier Neidhart and Daniel Schön, are happy to answer your questions.