ESG in Switzerland and Beyond: What Every Swiss Business Needs to Know

In today's rapidly evolving regulatory landscape, Swiss companies are facing mounting pressure—not just from Bern, but from Brussels, Paris, and Berlin too. Environmental, Social, and Governance (ESG) regulations are no longer just a checkbox for sustainability reports. They are a strategic imperative—and a reputational necessity.

So, how can Swiss companies, particularly SMEs, navigate this maze of regulations and rise to the challenge?

The answer lies in understanding both the Swiss legal framework and the ripple effects of European legislation. Let's unpack what matters—and how to stay ahead.

Swiss Legal Framework

Switzerland has taken bold steps to align with international climate goals, translating global ambitions into national law. Under Articles 964a to 964l of the Swiss Code of Obligations, large public interest entities—such as listed companies, banks, and insurance firms—that exceed two of the following thresholds (500 employees, CHF 20 million in assets, or CHF 40 million in revenues) must report on ESG topics annually.

These reports must:

• Include disclosures for climate-related risks and opportunities;
• Be approved by the board of directors;
• Remain publicly accessible for at least 10 years.

In addition, under Articles 964j to 964l CO, companies importing conflict minerals or offering products with potential child labour risks must implement due diligence and transparency measures.

While these obligations don't directly affect most SMEs, the ripple effect is undeniable. Increasingly, small and medium enterprises are expected to prove ESG compliance to remain competitive—especially in B2B markets, public procurement, and financial assessments.

The NUFG: Switzerland's Next Step

Switzerland is preparing its next major sustainability law: the Federal Act on Sustainable Corporate Governance (NUFG). Published by the Federal Council on 2 April 2026, the NUFG completed its public consultation in July 2026 and is now advancing toward parliamentary debate, with a vote expected in 2027. Direct reporting obligations will apply to companies with 1,000+ employees and CHF 450 million+ in turnover, while extended due diligence obligations—including supply-chain due diligence and civil liability provisions—cover companies with 5,000+ employees and CHF 1.5 billion+ in turnover. Implementation is not expected before 2029, following a two-year transition period after enactment.

Even companies below these thresholds should prepare: the NUFG's supply-chain provisions mean that large companies will request sustainability data from their SME suppliers.

Supportive National Initiatives

Switzerland's Climate and Innovation Act (LOCLI), in force since 2025, supports the country's 2050 net-zero goal with generous incentives—including up to CHF 200 million annually, tax breaks, and free advisory services. Even SMEs can benefit from programs like Reffnet and Suisse Energie to lower emissions and costs.

Even smaller companies can take advantage of this supportive framework to become part of the national solution—and boost their bottom line in the process.

The EU Impact on Swiss Companies

If your company operates abroad, supplies European clients, or aspires to grow beyond Swiss borders, EU regulations will touch your business—directly or indirectly.

CSRD and the Omnibus I Simplification

Following the EU Omnibus I simplification, enacted as Directive (EU) 2026/470 in March 2026, the CSRD's scope has been narrowed significantly. The new mandatory thresholds require 1,000+ employees AND €450 million+ in net turnover (both conditions must be met), exempting approximately 80% of previously in-scope companies. The European Commission also adopted revised European Sustainability Reporting Standards (ESRS) on 3 July 2026, reducing mandatory datapoints by over 60% and total datapoints by over 70%. These simplified standards apply from financial year 2027.

Despite the narrower scope, the CSRD remains in force. Double materiality assessment, third-party assurance, and digital reporting requirements all continue to apply. Swiss companies supplying EU-based customers above the new thresholds will still need to provide ESG data.

CSDDD: Due Diligence Obligations

The CSDDD applies to companies with 5,000+ employees and €1.5 billion+ in net worldwide turnover, with a single compliance deadline of July 2029 following the Omnibus I simplification (Directive (EU) 2026/470). The earlier phased-wave approach covering companies down to 1,000 employees has been eliminated. Mandatory climate transition plans were also removed. Swiss suppliers to these EU companies will need to provide due diligence data and documentation.

CBAM: The Carbon Border Tax

The EU's Carbon Border Adjustment Mechanism (CBAM) has been in full force since 1 January 2026, after a transition period of reporting-only obligations that ran from October 2023 to December 2025. Swiss companies exporting cement, electricity, fertilisers, iron, steel, aluminium, or hydrogen to the EU must now account for embedded carbon emissions, with EU importers required to purchase CBAM certificates. A simplification amendment (Regulation 2025/2083) introduced a de minimis threshold of 50 tonnes cumulative net mass per importer per year for most product categories, and moved the annual declaration deadline to 30 September. The Commission has also proposed extending CBAM to approximately 180 downstream aluminium and steel-intensive products from January 2028.

Swiss firms that are not prepared may quickly fall behind competitors or be excluded from EU procurement and partnerships. ESG compliance, once a nice-to-have, is now a market access requirement.

Five Smart Moves to Future-Proof Your Business

So, what should Swiss companies do? Here are five smart moves to future-proof your business:

1. Stay Informed – Anticipate legal changes by monitoring ESG developments in Switzerland and the EU, including the NUFG's progress through parliament.
2. Build a Strategy – Define an ESG roadmap with measurable goals and policies.
3. Map Risks – Understand your supply chain, identify ESG risks, and act on them.
4. Prepare for Proof – Get ready to meet client and investor requests with credible data.
5. Use Voluntary Tools – Embrace standards like EcoVadis, CDP, or ISO 14001, and leverage support programs such as Reffnet, SuisseEnergie, or CO2-reduction advisory services under LOCLI.

How Positive Organizations Can Help

At Positive Organizations, we specialize in guiding companies through the complexity of ESG compliance. Whether you're looking to develop a comprehensive sustainability strategy, calculate your carbon footprint or conduct a Life Cycle Assessment (LCA), pursue certifications such as B Corp, ISO, or CDP, or simply start with a 30-minute consultation to assess your current position, we're here to help you transform ESG obligations into strategic opportunities.

Let's make your impact positively powerful.

Looking for expert guidance? Explore our ESG Compliance, Regulations and Policies and ESG Reporting, Certifications and Ratings services to take the next step.