Swiss sustainability reporting requirements

Alignment of Swiss Sustainability Reporting Policies with International Standards

Switzerland's sustainability reporting landscape is undergoing significant transformation as the country works to align its corporate responsibility framework with evolving European and international standards.

Current Law: Articles 964a–l of the Code of Obligations

Under the current Swiss Code of Obligations (Articles 964a–964l), in force since 1 January 2024, large public-interest entities that exceed two of the following three thresholds must report on ESG topics annually: 500 employees, CHF 20 million in assets, or CHF 40 million in revenues. Approximately 300 companies fall under this obligation. Reports must be approved by the board of directors and remain publicly accessible for at least 10 years.

The June 2024 Consultation: Now Superseded

On 26 June 2024, the Swiss Federal Council launched a consultation to amend the Code of Obligations, proposing to lower reporting thresholds to 250 employees, CHF 25 million in assets, and CHF 50 million in turnover—which would have expanded the scope from approximately 300 to 3,500 companies. However, this consultation has been paused as of mid-2025, superseded by a more comprehensive legislative initiative: the NUFG.

The NUFG: Switzerland's New Sustainability Framework

The Federal Act on Sustainable Corporate Governance (NUFG — Bundesgesetz über die nachhaltige Unternehmensführung) was published by the Federal Council on 2 April 2026. Its public consultation closed on 9 July 2026, and the draft is now advancing toward parliamentary debate, with a vote expected in 2027 or early 2028.

The NUFG establishes two tiers of obligation:

• Reporting obligations: Companies with 1,000+ employees AND CHF 450 million+ in turnover (both conditions required)
• Extended due diligence obligations: Companies with 5,000+ employees AND CHF 1.5 billion+ in turnover, covering supply-chain due diligence and new civil liability provisions (approximately 30 Swiss companies)

Implementation is not expected before 2029, following a two-year transition period after enactment. A new oversight authority will be established to monitor compliance.

Why the Shift Matters for Swiss SMEs

While the NUFG's direct reporting obligations target larger companies, the ripple effects will be felt across the Swiss economy. Large companies subject to the NUFG's supply-chain due diligence requirements will increasingly request sustainability data from their SME suppliers and business partners. Companies that proactively prepare their ESG reporting capabilities will be better positioned to retain and win contracts in this evolving landscape.

Alignment with EU Standards

The NUFG's thresholds and approach closely mirror the EU's own reformed framework. Following the EU Omnibus I simplification (Directive (EU) 2026/470, enacted March 2026), the EU's CSRD now requires sustainability reporting from companies with 1,000+ employees AND €450 million+ in net turnover. The European Commission adopted revised European Sustainability Reporting Standards (ESRS) on 3 July 2026, reducing mandatory datapoints by over 60%. Swiss companies can choose between ESRS or equivalent standards that the Federal Council will define in a later ordinance.

This alignment means Swiss companies will operate under comparable standards to their European counterparts, maintaining competitive equality across markets and facilitating continued trade with EU partners.

What Companies Should Do Now

Even though the NUFG is not yet enacted, companies should begin preparing:

• Assess whether your company may fall within the NUFG's reporting or due diligence thresholds
• Start building internal ESG data collection and reporting processes
• Understand your supply chain's sustainability profile, as requests from larger partners will increase
• Consider voluntary frameworks such as EcoVadis, CDP, or ISO 14001 to build credibility ahead of mandatory requirements
• Monitor the NUFG's parliamentary progress and the Federal Council's forthcoming ordinance on equivalent reporting standards

The new framework should not be seen as a burden but as an opportunity for companies to embrace sustainable business practices, strengthen trust among partners and investors, and secure their competitive position in an evolving regulatory environment.

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

You may also be interested in: Preparing for the EU's Corporate Sustainability Reporting Directive (CSRD)