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Switzerland Non-Financial Reporting Requirements (Articles 964a–964c)

Switzerland Non-Financial Reporting Requirements (Articles 964a–964c): Swiss Non-Financial Reporting Law: Board-Level ESG Disclosure Obligations

Maílis Carrilho
Written by Maílis Carrilho
Updated on December 30th, 2025

Summary

Switzerland’s non-financial reporting requirements are set out in Articles 964a–964c of the Swiss Code of Obligations and impose mandatory ESG disclosure obligations on large companies. In-scope companies must publish an annual report covering environmental matters, climate risks, social and employee issues, respect for human rights, and anti-corruption measures. The report must describe policies, due diligence processes, key risks, and relevant performance indicators, or provide clear explanations where policies do not exist. Responsibility lies explicitly with the board of directors, and reports must be publicly accessible. While less prescriptive than the EU CSRD, the Swiss regime carries legal weight through corporate law and criminal sanctions, making accuracy and governance quality critical.

Details

Jurisdictions
  • Switzerland
Exemptions

Legally binding.

Applies to:

Industrial installations.

Energy and fuel suppliers.

Building owners (heating systems).

Exceptions:

The requirements apply only to companies exceeding statutory size thresholds; smaller companies fall outside scope.

Certain subsidiaries may be exempt if they are covered by an equivalent consolidated non-financial report at group level.

Companies may rely on the “comply or explain” principle, allowing omission of policies if adequately justified, but disclosure itself remains mandatory.

Deep dive

2 min read
Updated Dec 30, 2025

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What’s Required

Switzerland imposes mandatory ESG and sustainability reporting through corporate law, separate from the EU CSRD.

Key requirements include reporting on:

  • Environmental matters and climate risks.

  • Human rights.

  • Employee matters.

  • Anti-corruption measures.

Reports must be:

  • Published annually.

  • Approved by the board of directors.

  • Made publicly available.

Important Deadlines

  • Applies from the financial year 2023 onwards.

  • Annual publication.

Current Status

In force following the indirect counter-proposal framework that entered into force in 2022.

Penalties for Non-Compliance

  • Fines up to CHF 100,000 for missing or false reporting.

  • Criminal liability for knowingly making misleading statements.

Examples of Known Violations

  • Failure to publish a non-financial report within the required annual reporting cycle triggers enforcement risk under corporate law.

  • Incomplete ESG disclosures, particularly missing climate-risk or human-rights sections, are flagged by auditors, NGOs, or investors.

  • Misleading or inaccurate statements regarding environmental or human-rights practices expose board members to criminal liability under the Code of Obligations.

  • Public scrutiny cases where companies formally complied but faced reputational fallout for generic or boilerplate disclosures deemed inconsistent with actual operations.

Enforcement to date has focused more on credibility and truthfulness than volume of disclosure.

Closing Insights

Swiss non-financial reporting law is often perceived as lighter than EU CSRD, but this is misleading. The regime relies on criminal liability for false or misleading statements and clear board-level accountability, shifting risk from volume of disclosure to quality and truthfulness. For companies in scope, governance discipline and internal controls matter more than extensive reporting frameworks, making this a high-trust but high-risk disclosure regime.

Resources


Maílis Carrilho
Added by:
Maílis Carrilho
Sustainability Research Analyst
Maílis Carrilho is a Sustainability Research Analyst (Intern) at Net Zero Compare, contributing research and analysis on climate tech, carbon policies, and sustainable solutions. She supports the team in developing fact-based content and insights to help companies and readers navigate the evolving sustainability landscape.
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Added on Dec 29, 2025 by Maílis Carrilho · Updated on Dec 30, 2025