Overview of the Ordinance on Climate Disclosures
Introduced: November 2022 (Federal Council ordinance)
Effective from: FY 2024 (first reports published in 2024/25)
Last modified: December 2024 (consultation on ISSB incorporation)
Region(s): Switzerland
About the Ordinance on Climate Disclosures
Switzerland’s Ordinance on Climate Disclosures mandates transparent, investor-grade reporting for large public-interest entities.
Initially based on TCFD principles and emphasizing double materiality, the regulation requires companies to disclose both climate-related financial risks and environmental impacts.
From 2025, companies may align with ISSB’s IFRS S2 to ensure compatibility with global frameworks like the EU CSRD, reinforcing Switzerland’s position as a sustainability leader in finance and corporate governance.
Criteria for compliance
Entities meeting both of the following thresholds for two consecutive years:
- At least 500 employees
- Either CHF 20 million in total assets or CHF 40 million in annual turnover
Additional scope:
- Banks and insurers with total assets ≥ CHF 20 billion, regardless of employee count
- Swiss subsidiaries may report under a consolidated parent disclosure if equivalent in scope
Disclosure requirements
- Governance structure for climate oversight
- Climate-related risks and opportunities in company strategy, including alignment with 1.5°C scenarios
- Risk management procedures for identifying and mitigating climate impact
- Scope 1, 2, and 3 GHG emissions
- Offsets used, interim targets, and progress toward Switzerland’s 2050 net-zero commitment
- Transition plan and timeline
- Reports must be accessible online for 10 years
Key obligations
- Climate data must be included in a standalone report or embedded in the Non-Financial Report
- Board approval required
- Must be filed in machine-readable format from 2025 onward
Third-party assurance
Currently, auditors only confirm the report’s existence, not its content. Voluntary limited assurance is common, particularly among multinationals. The Swiss government is reviewing whether to mandate assurance beginning in 2027.
Penalties for non-compliance
Noncompliance may trigger:
- Fines under the Swiss Code of Obligations
- Reputational damage with NGOs, investors, and regulators
- Shareholder lawsuits for directors failing to fulfill fiduciary duties
- Auditor disqualification if disclosure is missing
