What are Scope 3 greenhouse gas emissions?
August 18, 2024
Switzerland is tightening its requirements on both sustainability reporting and corporate due diligence. The Swiss Federal Council published a new legislative proposal in April 2026 that would significantly expand what large Swiss companies, and Swiss entities of foreign multinationals, are required to disclose and demonstrate.
What the proposal covers
On reporting, the proposal introduces more structured sustainability disclosure requirements for large companies, including mandatory climate disclosures covering emissions, climate-related risks, targets, and transition plans. The framework is aligned with TCFD, making it compatible with the climate disclosure infrastructure many larger companies have already started building.
On due diligence, the proposal broadens existing obligations substantially. Switzerland currently requires due diligence specifically on child labour and conflict minerals. The new proposal extends that scope to a wider range of human rights and environmental risks across operations and supply chains, bringing Switzerland closer to the expectations already embedded in the EU’s Corporate Sustainability Due Diligence Directive.
Why this matters beyond Swiss-headquartered companies
The proposal applies to companies meeting defined size thresholds and reaches Swiss entities of foreign multinationals. For groups with EU operations already preparing under CSRD, the climate disclosure overlap is meaningful. TCFD-aligned disclosures share a common data foundation with ESRS E1 requirements: Scope 1 and Scope 2 emissions, scenario analysis, and transition plan information are required under both. A well-structured CSRD preparation process reduces the incremental effort for Swiss compliance considerably.
For multinationals with Swiss entities but no EU reporting exposure, this proposal is a new obligation to plan for. The due diligence extension in particular will require a supply chain mapping and risk assessment exercise that goes well beyond what existing Swiss requirements demand.
What to do now
The proposal is at the consultation stage, but the direction is clear. Large Swiss companies and groups with significant Swiss operations should assess their current disclosure and due diligence baseline against the proposed requirements. Starting that gap assessment now, while the legislative text is still taking shape, leaves time to build the right processes before obligations become binding.
“We are seeing this pattern across jurisdictions: the question is no longer whether mandatory sustainability reporting will apply, but when. Starting the preparation work now, under any framework, builds a foundation that transfers.”
Jatin BudhrajaSustainability Advisory Director
Our team works with companies across Switzerland and the EU on sustainability reporting across jurisdictions. Download our reporting guide to learn more about global frameworks!
