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Switzerland Ordinance on Climate Disclosures

Switzerland Ordinance on Climate Disclosures: Switzerland Climate Disclosures: Mandatory TCFD Reporting for Large Companies

Maílis Carrilho
Written by Maílis Carrilho
Updated on May 28th, 2026

Summary

Switzerland’s Ordinance on Climate Disclosures makes TCFD-aligned climate reporting mandatory for large companies from 1 January 2024. In-scope firms must disclose governance, strategy, risk management, and metrics and targets, typically for FY2024, with first publications in 2025. The regime increases legal and reputational risk for missing or misleading climate statements and pushes companies to formalise transition plans and climate-risk integration in governance. Switzerland has also initiated consultations to update the ordinance in line with evolving international standards.

Details

Jurisdictions
  • Switzerland
Mandatory for

Legally binding for in-scope large companies (including major financial institutions), with public reporting obligations.

Exemptions

Companies below scope thresholds are out of scope (scope is size-based).

Group-structure and consolidation approaches can affect who reports (often via consolidated reporting pathways).

Deep dive

3 min read
Updated May 28, 2026

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What's Required

Covered companies must publish climate-related disclosures as part of their non-financial reporting.

Organizations may need to:

  • Assess whether they fall within the Swiss Code of Obligations non-financial reporting scope.

  • Report climate-related financial risks and impacts.

  • Disclose governance arrangements for climate-related matters.

  • Describe climate-related strategy and resilience.

  • Explain climate risk identification, assessment and management processes.

  • Report climate-related metrics and targets.

  • Disclose greenhouse gas emissions, including direct and indirect emissions.

  • Publish reduction targets and explain how they intend to implement them.

  • Address both the impact of climate change on the company and the company’s impact on the climate.

  • Publish the report in a human-readable and machine-readable electronic format.

  • Make the report publicly available.

The ordinance follows a TCFD-based structure and includes a double-materiality approach.

Important Deadlines

  • January 1, 2024: The Ordinance on Climate Disclosures entered into force.

  • Financial year 2024: In-scope companies began reporting under the ordinance.

  • 2025: First reports for financial year 2024 are generally expected to be published, depending on each company’s reporting calendar.

  • March 21, 2025: Consultation closed on proposed amendments to the ordinance.

  • June 25, 2025: The Federal Council decided to pause the revision of the ordinance pending clarity on broader Swiss sustainability reporting reforms and EU regulatory developments.

Current Status

The Switzerland Ordinance on Climate Disclosures is currently in force.

The Federal Council adopted the ordinance in November 2022 and brought it into force on January 1, 2024. It applies to companies already covered by the Swiss Code of Obligations rules on non-financial reporting, generally large public-interest entities with at least 500 employees and either CHF 20 million in total assets or CHF 40 million in turnover.

The ordinance itself remains active. However, planned amendments to update and expand the rules have been paused while Switzerland considers broader changes to sustainability reporting and monitors regulatory developments in the European Union.

This means companies currently in scope should continue applying the existing ordinance, while monitoring future changes.

Penalties for Non-Compliance

  • Statutory fines

Non-compliance is linked to the penalty provisions for non-financial reporting under Swiss law.

Potential consequences may include:

  • Fines for failure to prepare or publish required climate disclosures.

  • Fines for false or misleading information in the report.

  • Liability risks for responsible directors or executives.

  • Regulatory scrutiny from Swiss authorities.

  • Investor, lender, customer and public pressure.

  • Increased litigation or greenwashing risk where disclosures are incomplete or misleading.

Under Swiss law, intentional breaches of non-financial reporting obligations may lead to fines of up to CHF 100,000. Negligent breaches may lead to fines of up to CHF 50,000.

Examples of Known Violations

As of May 2026, we were not able to find publicly available examples of specific penalties imposed under the Switzerland Ordinance on Climate Disclosures against named companies.

This is likely because the ordinance only entered into force on January 1, 2024 and first reporting cycles are still recent.

However, companies may face enforcement, reputational damage or investor scrutiny if they fail to publish required climate disclosures or provide inaccurate information.

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 May 27, 2026 by Maílis Carrilho · Updated on May 28, 2026