On 6 December 2024, the Swiss Federal Council launched a consultation process until 21 March 2025 to amend the Ordinance on Climate Disclosures in order to reflect recent regulatory developments in the EU and to set minimum requirements for transition plans. What does this mean for Swiss companies?
Proposed amendments to the Ordinance on Climate Disclosures
On 6 December 2024, the Swiss Federal Council launched a consultation on amendments to the Climate Ordinance, impacting companies which are required to produce non-financial reports under the Swiss Code of Obligations (CO). The scope would be aligned with the future amended scope of Art. 964a-c of the CO resulting from the consultation on Swiss non-financial reporting whose the outcome is expected by mid-2025.
While the current Ordinance is based on the fulfilment of the Task Force on Climate-related Financial Disclosures (TCFD) recommendations, the dissolution of TCFD has prompted a shift to accepting other internationally recognized standards, specifically, the European Sustainability Reporting Standards (ESRS) and IFRS International Sustainability Standards Board (ISSB) S2 (which replaced the TCFD recommendations while building upon its original principles). In the EU, the European Financial Reporting Advisory Group (EFRAG) published in November 2024 its latest draft Implementation Guidance on transition plans, similarly basing it on the ESRS disclosure requirements for the transition plan with reference to climate change mitigation in accordance with ESRS E1-1, para. 16.
The proposed amendments to the Ordinance includes the following key changes:
Disclosures based on an internationally recognized standard such as ESRS and IFRS ISSB S2;
Mandatory implementation of a net-zero roadmap, synonymous with a “transition plan”;
Reporting in an electronic format, which is not only human and machine readable, but which also allows the publication on an international platform (e.g. ESEF); and
Whenever possible and appropriate, disclosures in quantitative format to guarantee comparability of material assumptions, methodologies and standards.
Net-zero roadmap – background and purpose in a nutshell
Switzerland signed the Paris Agreement and agreed to achieve a net-zero emissions balance (climate neutrality) by 2050. According to article 5 of the Swiss Climate and Innovation Act, which is enforced as of the 1 January 2025, all companies must contribute to this net-zero goal and, according to paragraph 2, should establish net-zero roadmaps to achieve the defined target.
What is a net-zero roadmap?
A “net-zero roadmap”, synonymous with a “transition plan”, is a strategic document that helps your company to align your business activities, assets and behaviors with a 1.5°C scenario. The credibility of this plan hinges on the extent of disclosed climate indicators and the robustness of the associated monitoring processes. The disclosure of these plans equips investors with the information needed to finance the transition at the required pace and scale.
As mentioned above, one of the key amendments to the Ordinance is the introduction of a mandatory net-zero roadmap to be integrated into the report on non-financial matters as per Articles 964a-c of the CO. The sustainability report must be machine-readable and updated in the event of significant changes, enhancing transparency. The minimum criteria vary for real economy companies (i.e. non-financial industry) and financial companies to account for differences in principal business activities:
For real economy companies i.e. non-financial industry: companies are expected to fulfil the requirements outlined in the Climate Mitigation Ordinance “Klimaschutzverordnung” (KIV) and the Climate and Innovation Act, in line with net-zero ambition by 2050 and associated interim reduction targets.
For financial companies: FINMA regulated undertakings such as banks, insurance companies, and asset managers must comply with specific minimum requirements regarding net-zero roadmaps for the climate-friendly alignment of financial flows that describe the planned path to the net-zero target by 2050; the roadmaps should differentiate between asset classes (e.g., real estate, equity, corporate bond portfolios) and include science-based targets. These targets must be set at group level, encompassing emissions produced outside of Switzerland. The trajectory is recommended to be defined with interim targets for 2030 and 2040, with certain asset classes and sectors recommended to also include 2035 and 2045 targets. Where feasible and appropriate, scope 3 emissions category 15 should include the emissions of the up- and down-stream chain of activities of the financed and/or investee companies.
The Federal Council suggests basing the net-zero roadmap on international best practices, such as the framework of the Transition Plan Taskforce (TPT) or the Glasgow Financial Alliance for Net Zero (GFANZ), providing, where possible and appropriate, forward-looking information on planned actions, particularly in the areas of governance, strategy, resources and risk management.
Though still under consultation until 21 March 2025, with a planned entry into force on 1 January 2026, this proposal signals Switzerland's commitment to robust, internationally harmonized climate reporting.
How PwC can help you
Our services are designed to help businesses in Switzerland and across the EU meet evolving sustainability reporting obligations with confidence and precision.
We can perform scoping and gap assessments to determine the extent to which you are affected by the proposed new version of the Climate Disclosure requirements.
For companies affected by the Ordinance on Climate Disclosures, we offer expert guidance in developing comprehensive transition plans aligned with the proposed amendments, ensuring compliance and clarity.
Additionally, for companies subject to the EU's Corporate Sustainability Reporting Directive (CSRD), we provide tailored support to navigate the complexities of ESRS disclosure requirements and interconnections with other regulatory requirements.
Finally, we provide pre-assurance services as well as independent assurance opinions regarding your non-financial disclosures according to the European and Swiss regulatory requirements to ensure transparency of your disclosures and trust in your disclosures.
