Event EN0419

Sustainability Reporting in Switzerland: Current Status

Regulatory requirements for sustainability reporting in Switzerland are undergoing further change.

Background

- In May 2025, the popular initiative “For responsible large companies – for the protection of people and the environment”, also known as the Corporate Responsibility Initiative 2.0 (CRI 2.0), was submitted. One of the key objectives of CRI 2.0 is to define compliance with greenhouse gas emission reduction pathways as a binding obligation of result.
- On April 2, 2026, the Federal Council presented a counterproposal to CRI 2.0, which is currently open for consultation until July 9, 2026.

Key elements of the counterproposal (selection):

- Scope of application virtually identical to that of the EU CSRD Omnibus Directives:

Reporting obligations (scope of application)

- - Swiss companies: 1,000 employees and global net revenue of CHF 450 million
    (previously: more than 500 employees and total assets of CHF 20 million or revenue of CHF 40 million)
  - Non-Swiss companies: Net revenue in Switzerland of CHF 450 million and a subsidiary or branch in Switzerland

Due diligence obligations (scope of application):

- - Swiss companies: 5,000 employees and global net revenue of CHF 1.5 billion
    (previously: companies exceeding certain import or processing thresholds)
  - Non-Swiss companies: Net revenue in Switzerland of CHF 1.5 billion

- Small and medium-sized enterprises (SMEs):

Large companies may request information from SMEs with fewer than 1,000 employees only if the information:

- - is commonly exchanged within the industry, and
  - is based on internationally recognized, voluntary standards for non-reporting companies designated by the Federal Council.

- Liability and sanctions:

Breach of due diligence obligations: Monetary sanctions of up to 3% of global net revenue, as well as public disclosure of the sanctions
Violations of reporting obligations: Criminal fines of up to CHF 100,000

What it means for your company?

The scope of application is largely aligned with the EU CSRD omnibus directives. It remains unclear how further proposals from the consultation process will be incorporated into the Federal Council’s counterproposal.
One point remains clear: companies that already apply CSRD/ESRS, GRI, or another international standard in their sustainability reporting are well prepared to meet future Swiss sustainability reporting requirements.

We will keep you informed!

Please feel free to contact us for an informal discussion if you have any questions.

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