Ordinance on Climate Disclosures

Ordinance on Climate Disclosures: mandatory tcfd/issb-aligned climate governance, risk and scope 1, 2 and 3 emissions disclosure with transition plans for large swiss entities.

Jurisdiction
Status
active
Category
climate
First deadline
FY2024 (first reports published in 2024/25)
Who must comply
Applies to large Swiss public-interest entities meeting both thresholds for two consecutive years: at least 500 employees and either CHF 20 million in total assets or CHF 40 million in annual turnover. Also captures banks and insurers with total assets of at least CHF 20 billion regardless of employee count, and Swiss subsidiaries may report under a consolidated parent disclosure.
Penalties
Fines under the Swiss Code of Obligations, reputational damage with NGOs, investors and regulators, shareholder lawsuits for directorial breach of fiduciary duty, and auditor disqualification if disclosure is missing.

What it is

Switzerland's Ordinance on Climate Disclosures, issued by the Federal Council, mandates transparent, investor-grade climate reporting for large public-interest entities.

Initially based on TCFD principles and emphasizing double materiality, it requires companies to disclose both climate-related financial risks and environmental impacts, and from 2025 companies may align with ISSB's IFRS S2 for compatibility with global frameworks like the EU CSRD.

Who must comply

Applies to entities meeting both thresholds for two consecutive years: at least 500 employees and either CHF 20 million in total assets or CHF 40 million in annual turnover. Banks and insurers with total assets of at least CHF 20 billion are in scope regardless of employee count, and Swiss subsidiaries may report under a consolidated parent disclosure where equivalent in scope.

What you must disclose

Companies must disclose their climate governance structure, climate risks and opportunities aligned with 1.5C scenarios, risk management procedures, and Scope 1, 2 and 3 GHG emissions. Disclosures also cover offsets, interim targets, net-zero alignment and a transition plan and timeline, with Board approval, ten-year online accessibility, and a machine-readable format from 2025.

Timeline

Introduced by the Federal Council in November 2022 and effective from fiscal year 2024, with first reports published in 2024/25.

A machine-readable format is required from 2025 onward, and companies may align with ISSB's IFRS S2 from 2025. Last modified December 2024 during consultation on ISSB incorporation, with a potential assurance mandate under review from 2027.

Stay ahead of this regulation.

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