Blog ESRS

From Brussels to Bern: how Swiss companies can leverage the power of ESRS

Swiss parliament
  • Blog
  • 5 minute read
  • 06/10/23

The European Sustainability Reporting Standards (ESRS) are shaping the way businesses report on sustainability. What does this mean for Swiss companies, and how can they leverage it to their own advantage?


Dr. Philipp Thaler
Senior Manager, Sustainability and Climate Change
PwC Switzerland

Ralf Hofstetter
Director, Leader Trust & Transparency Solutions
PwC Switzerland


Over the past years, sustainability and ESG criteria have transitioned from a peripheral concern to a core topic across society, politics, businesses, and investors. As a part of the global shift towards sustainable development and achieving net zero, the European Parliament and Council introduced the Corporate Sustainability Reporting Directive (CSRD). The details how companies have to disclose their non-financial information under this directive are specified in the European Sustainability Reporting Standards (ESRS), marking a significant stride in transparency and standardised sustainability reporting. In July 2023, the first set of these standards was released by the European Commission. What does this mean for Swiss companies?

CSRD and ESRS: sustainability through disclosure

The primary objective of both CSRD is to promote sustainable business practices with the aim to address market failure resulting from a lack of information among various players. The ESRS form the CSRD’s main instrument for achieving this objective through:

  1. establishing transparency in business operations through comprehensive disclosures, and, at the same time,
  2. creating an applicable standard to enable true comparability.

It’s interesting to note that these regulations don’t impose specific ESG obligations but compel companies to disclose comprehensive information instead. The ESRS embodies a distinctly neoliberal market approach, emphasising transparency rather than prescriptive targets or measures. By mandating companies to disclose specific information, it not only creates market pressure but also signals a clear belief: transparency drives sustainability. As informed markets favour more sustainable enterprises, companies that prioritise sustainable practices stand to gain, while those that lag are risking competitive disadvantage. Ultimately, this should encourage industry-wide sustainable progression.

The mere obligation of disclosure has stirred significant movement in the market. Beyond simply meeting the disclosure norms, businesses are actively analysing industry benchmarks, competitor stances, and viable opportunities to bolster their sustainability practices. Take CO2 emissions, for instance: While companies are required to disclose their emissions, there isn’t an imposed mandate on reducing them. Yet, many firms voluntarily establish and announce reduction targets. These self-imposed benchmarks not only foster an internal drive towards greener transitions but also heighten external competitive standards, compelling industry peers to increase their sustainability efforts.

At first glance, ESRS may come across as an intricate regulatory colossus. Yet, its foundation is built upon familiar terrains:

  • a modular structure, analogue to the Global Reporting Initiative (GRI);
  • a reporting approach to disclose information on four core themes (governance; strategy; impact, risk and opportunity management; metrics and targets) for each material topic, inspired by the Taskforce on Climate-related Financial Disclosures (TCFD); and
  • the concept of double materiality, which was already introduced by the EU in 2019 in the guidelines on reporting climate-related information. The first, “impact materiality”, adopts an inside-out lens, capturing the company’s imprint on the environment, society, and other external factors, borrowing its essence from GRI standards. Conversely, “financial materiality” employs an outside-in perspective, assessing the influence of external factors like the environment, economy, and societal issues on the company’s financial standing. This approach is geared towards the information requirements of investors and mirrors the approach of the American Sustainability Accounting Standards Board (SASB).

The CSRD/ESRS’ dual character as a robust law and a defining standard is also noteworthy. It’s unprecedented for a major piece of legislation to shape the standard directly, rather than drawing from norms established by non-profit organizations. This evolution in sustainability reporting is far-reaching and provides unparalleled transparency and comparability, not least because it requires companies to obtain limited assurance on their ESRS reports or key performance indicators. Given that in the EU alone over 50,000 companies come under its purview while its impact extends to many more multinational firms outside EU borders, the ESRS is undeniably setting a new standard for mature sustainability reporting practices around the globe.

This ambitious standard, while seeming overwhelming, garners widespread industry support. Having undergone multiple consultation rounds, the ESRS is not merely a top-down imposition but based on the EU Commission’s active engagement with the business and non-profit community. 

The CSRD and ESRS are clearly EU regulations, but by creating sustainability through transparency, they transcend borders and as such also affect Swiss companies.

For Swiss companies, the entry into force of CSRD and the adoption of ESRS, though European in origin, holds tangible significance. Even if many of them are not directly subject to EU sustainability reporting rules, the intertwined nature of international markets and supply chains, especially with European partners, makes it imperative for Swiss businesses to take note of them. While Swiss companies with large and/or listed subsidiaries in the EU directly fall under the regulations, also for smaller and mid-sized Swiss firms engaged in European supply chains, adopting the ESRS is not just a matter of compliance but also a strategic move.

It presents an opportunity to showcase not just metrics but a holistic perspective on governance, risks, impact, and overall business sustainability. As the market, including industry leaders and investors, clamours for transparency and comparability, the ESRS serves as a guide, accelerator, and incubator for a company’s sustainability transformation. 

Thereby, Swiss companies shouldn’t approach ESRS with fear, but they should accord it due respect, as the influence of ESRS can be felt through market demands and integrated supply chains. Moreover, Swiss regulations are set to either adapt or align with EU standards on sustainability reporting, as the Federal Council has announced. Therefore, for Swiss businesses, keeping pace with ESRS isn’t merely about staying relevant; it’s about envisioning a future where sustainability and competitive advantage go hand in hand.

The Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) hold significant implications for Swiss enterprises. As the EU heightens its sustainability reporting standards, Swiss firms with EU-based subsidiaries might feel the ripple effects. The rollout of these enhanced standards will observe a phased timeline:

  • From 1 January 2024 (reporting on financial year 2024 data): Companies previously falling under NFRD, as well as large EU companies and third country companies with securities listed on an EU exchange. 
  • From 1 January 2025 (reporting on financial year 2025 data): All large companies (including large EU subsidiaries of non-EU parent companies) that were not covered by the NFRD and meet two of the following three criteria:
    - more than 250 employees
    - 40 million € turnover
    - € 20 million balance sheet. 
  • From 1 January 2026 (reporting on financial year 2026 data; 2-year opt-out possible): All SMEs with securities listed on an EU exchange.
  • From 1 January 2028 (reporting on financial year 2028 data): Third country parent companies with at least one large EU subsidiary (or a branch > € 40 million turnover) and > € 150 million consolidated turnover in the EU. 

Next steps for Swiss firms

For Swiss companies navigating the complexities of sustainability reporting, the immediate future is full of critical considerations. A five-step approach can guide you through the maze:

  1. Initial assessment: The first step for Swiss firms is to undertake a comprehensive assessment of the applicability of non-financial reporting regulations and their current sustainability reporting practices. This includes a legal scoping against relevant sustainability regulations, identifying data sources, evaluating existing strategies and policies, and understanding the gaps in alignment with ESRS and other regulatory requirements.
  2. Strategic prioritisation: It's crucial to prioritise key areas for improvement rather than trying to address all issues simultaneously. Through strategic prioritisation, organisations can efficiently allocate their IT, financial, and human resources to the tasks that will have the greatest impact.
  3. Data verification: Ensure that the data underpinning your reports is robust and verifiable to withstand external scrutiny. Establishing a systematic process for data collection and verification is fundamental for accurate and reliable reporting.
  4. Assurance: A trusted assurance provider is essential to ensure that your final sustainability reports comply with all regulatory and procedural requirements. Engage with a reputable assurance provider to perform the assurance engagement and subsequently release the public assurance report.
  5. View the ESRS as a valuable guide: Instead of treating ESRS as a mere compliance obligation, use it as a valuable guide to improve your sustainability practices. ESRS prompts an in-depth review of governance, impact risks, and business fit, which can facilitate a shift towards a more sustainable business model.

How PwC can help

In the evolving landscape of ESRS and sustainability reporting, PwC stands as your strategic partner. Here is how we can support you: 

  • Action plan development: PwC can help you develop a detailed action plan tailored to your organisation's unique needs and circumstances. Our collaborative approach ensures that we understand your specific requirements, sustainability reporting practice and gaps in your current disclosures to help you navigate the ESRS and sustainability reporting landscape effectively.
  • ‘One report fits all’ strategy: Given the overlaps between ESRS and Swiss sustainability reporting, a streamlined ‘one report fits all’ approach could be beneficial. We aim to simplify the reporting process and minimise the burden, while ensuring compliance and meaningful insights.
  • Continuous collaboration: Our commitment doesn’t end with the development of an action plan. We remain a strategic partner, offering ongoing support and guidance as you implement the ESRS, constantly align with the evolving sustainability standards, and help you stay ahead of the sustainability curve.
  • Transformation vision: PwC not only guides you through compliance, but also helps you envision and realise a transformative sustainability journey. Our approach ensures that your path to sustainability is not just clear, but transformative.
  • Trusted assurance partner: PwC is your trusted assurance partner to audit your sustainability indicators and subsequently issue an assurance opinion.

This approach, combined with PwC's expertise, aims to provide Swiss companies with a straightforward guide to improving their sustainability reporting and overall business sustainability.

Contact us

Dr. Philipp Thaler

Senior Manager, Sustainability & Climate Change, Zurich, PwC Switzerland

+41 79 422 62 08

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Ralf Hofstetter

Partner, Sustainability Assurance, PwC Switzerland

+41 58 792 5625

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