Swiss Federal Council pushes forward with revised climate reporting ordinance; finance sector transition plans under scrutiny
In a decisive move to elevate climate transparency and bring Swiss corporate reporting in line with international expectations, the Swiss Federal Council (Bundesrat) is advancing plans to revise the Ordinance on Climate-Related Reporting just 18 months after its initial implementation.
The proposed amendments, presented by the Federal Department of Finance (EFD) and outlined in the official government release, are intended to reinforce Switzerland’s commitment to the Paris Agreement, implement elements of the Climate Protection Act (KlG), and keep pace with evolving EU legislation, particularly the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).
Background: a fast-tracked reform
Switzerland’s climate reporting ordinance, based on the Task Force on Climate-related Financial Disclosures (TCFD), came into force on 1 January 2024. Initially, the Federal Council had planned to review the ordinance by 2027. However, due to the adoption of the Klimaschutzgesetz and increasing EU regulatory activity, the review has been significantly expedited, with updated rules now targeted for implementation by January 2026.
The revisions aim to:
- Introduce minimum requirements for climate transition plans in the financial sector;
- Increase comparability and reliability of climate disclosures;
- Harmonise Swiss requirements with emerging global and European sustainability reporting standards, especially the ISSB and ESRS frameworks.
Consultation outcome: broad support with key reservations
The consultation, held from December 2024 to March 2025, drew 91 responses, including:
- 23 cantons;
- 5 national political parties;
- multiple financial and industry associations, including economiesuisse, Swiss Sustainable Finance (SSF), and SwissHoldings;
- NGOs and advocacy groups, such as WWF, Pro Natura, and Public Eye.
According to the summary report, 81 participants supported the revision, either outright or with caveats. Only five, including the FDP and SGV (Swiss Trade Association), opposed the plan outright, mainly citing administrative burden and poor timing.
Key proposed changes: toward sharper disclosure and target-driven reporting
Alignment with International Standards
A central pillar of the revision is the explicit alignment with international sustainability reporting standards. Many respondents welcomed this shift, though some urged Switzerland to prioritise the EU’s ESRS standards due to their “double materiality” lens — accounting for both financial and environmental/social impacts — in contrast to the more financially focused ISSB approach.
Some also called for recognition of GRI Standards as equally valid, advocating flexibility in selecting frameworks, provided they meet the ordinance’s core requirements.
Mandatory climate transition plans for financial institutions
One of the most closely watched elements is the requirement for financial sector players to produce transition plans, outlining:
- Emissions reduction targets (including interim targets for 2031–2040 and 2041–2050);
- Investment strategies aligned with Switzerland’s net-zero 2050 goal;
- Differentiation by asset class and sector.
NGOs such as WWF and Greenpeace welcomed this as a critical mechanism for aligning capital flows with climate goals. However, asset managers (e.g. AMAS, SSF) raised concerns about fiduciary conflicts and warned against a uniquely Swiss “gold-plated” approach, urging flexibility and deferral until EU regulations are finalised.
Scope 3 Emissions and reporting detail
Numerous respondents urged that Scope 3 (value chain) emissions be explicitly addressed in transition plans. While civil society groups strongly supported mandatory inclusion, industry associations preferred making it optional, citing data availability and cost challenges.
Several cantons and climate groups also advocated for more granular disclosure of reduction measures distinguishing between direct emissions cuts, offsetting, and carbon removal and called for the removal of vague language like “where possible and appropriate” from the reporting requirements.
Implementation & Oversight: gaps identified
Despite broad support, stakeholders highlighted notable gaps:
- No oversight mechanism: Several parties, including the SP and Green Party, criticised the lack of a supervisory body to enforce compliance or verify transition plan credibility.
- Reporting Format & Accessibility: Concerns were raised about the requirement to publish disclosures in formats compatible with international platforms. Civil society groups advocated for standalone publication of transition plans, rather than embedding them solely within general sustainability reports.
There were also calls for public templates, sectoral pathways, and benchmarking tools to help companies meet new expectations efficiently.
Timing and transitional provisions: A contentious point
Many respondents, including economiesuisse, Swiss Medtech, and the Canton of Geneva argued that the 2026 start date is too soon, especially given the ordinance only took effect in 2024 and the EU’s own framework is still in flux.
Industry groups are lobbying for a one- to two-year grace period, with a formal review scheduled two years post-implementation to assess the regulation’s practicality.
Terminology debate: ‘Fahrplan’ vs. ‘Transition Plan’
The proposed shift in terminology from “Transition Plan” to the German “Fahrplan” (climate roadmap) sparked debate. Supporters argue it aligns with the Swiss Climate Protection Ordinance (KlV), while critics — including NGOs and business groups — warned it may create confusion and weaken international alignment.
Next Steps: policy finalisation and EU coordination
The Federal Council is expected to finalise the revised ordinance by end of 2025, with a keen eye on parallel developments in Brussels. Switzerland’s challenge remains finding the sweet spot between regulatory coherence with the EU, market competitiveness, and climate leadership.
For the full results of the consultation and list of participating organisations, visit the page in german here.
