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Switzerland

Mandatory from 2024

Swiss Climate Disclosure Ordinance

Switzerland's Climate Disclosure Ordinance (OR 964a–964c CO), effective 1 January 2024, mandates climate-related financial disclosures for large public companies, including banks, insurers, and asset managers. The framework aligns with TCFD and ISSB S2, with FOEN guidance ensuring interoperability with the EU's CSRD/ESRS to support cross-border comparability. Switzerland applies a double materiality approach, requiring firms to disclose both the financial impacts of climate risks and their own environmental impacts.

Key Requirements

  • Transition and physical climate risk disclosures across multiple time horizons
  • Governance, strategy, and board-level climate expertise
  • GHG emissions reporting (Scopes 1, 2, and 3), including financed emissions for financial institutions
  • Scope 3 Category 15 financed emissions reporting aligned with PCAF
  • Scenario analysis using NGFS and Swiss Federal Council climate pathways
  • Disclosure of Paris Agreement alignment, targets, and progress tracking
  • Interoperability with EU CSRD/ESRS standards for consistency across jurisdictions
  • Integrated reporting in CHF and official languages (DE/FR/IT/EN)
  • Limited assurance from Year 1, with a roadmap to reasonable assurance

Implementation Timeline

In force 1 January 2024
First reports due in 2025 (covering FY2024)
Transitional relief: simplified Scope 3 reporting permitted for first two years; SMEs exempt

Report Timing

Annual, aligned with fiscal year (typically 1 January – 31 December); sustainability disclosures included in the annual report.

Compliance Status

Mandatory from 2024

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