Vlad Kalashnikov is Head of Products at CFOUR Comply, an inline XBRL (iXBRL) conversion software. Through direct involvement in customer onboarding, he works closely with teams navigating these requirements, giving him firsthand insight into the operational realities firms face with tagging and the challenges corporate service providers encounter delivering these services at scale.
The Ordinance on Climate Disclosures has applied to large Swiss companies, banks, and insurers since 1 January 2024, and the Federal Council confirmed its position on the reporting format as recently as September 2025. This article sets out the current scope, content, and format requirements with all recent developments and updates by 2026.
Swiss Climate Ordinance, Switzerland’s Climate Disclosure Requirements Explained
Who Has to Report Under the Swiss Climate Ordinance
The Swiss Ordinance on Climate Disclosures has applied since 1 January 2024. It requires large Swiss public companies and companies supervised by FINMA, including banks and insurers, to report publicly on climate-related matters. The threshold for inclusion is 500 or more employees combined with either CHF 20 million in total assets or CHF 40 million in turnover, measured on a consolidated basis including controlled entities abroad, assessed over two successive financial years. These requirements sit within Articles 964a-c of the Swiss Code of Obligations, the same statutory basis that governs Switzerland’s wider non-financial reporting rules.
In-scope companies must disclose two categories of information. The first is the financial risk the company faces because of climate-related developments. The second is the impact of the company’s own business activities on the climate. Alongside these disclosures, companies must set out their greenhouse gas reduction targets, covering direct and indirect emissions, and describe the measures they are taking to meet them.
The obligation aligns closely with Switzerland’s wider ESG reporting requirements.
Companies that also fall within scope of the EU’s Corporate Sustainability Reporting Directive often find the underlying data collection overlaps significantly, even though the Swiss Climate Ordinance and CSRD remain separate regimes with distinct legal bases, thresholds, and enforcement bodies.
What the Task Force on Climate-Related Financial Disclosures Requires
The Swiss Climate Ordinance is built on the recommendations of the Task Force on Climate-Related Financial Disclosures, referencing both the June 2017 recommendations and the October 2021 implementation annex. Reporting must follow those recommendations across four categories – governance, strategy, risk management, and metrics and targets.
The first climate disclosures under the Ordinance covered the 2024 financial year and were published during 2025. Machine-readable reporting was scheduled to follow one year after the Ordinance came into force, so the requirement applies in full from the 2025 reporting period, with those reports due during 2026.
Reporting Format, Human-Readable and Machine-Readable
The Ordinance requires disclosures in a format that is both human-readable and machine-readable. Early commentary from XBRL International described this as an implicit XBRL mandate, since a PDF alone cannot satisfy the machine-readable half of that requirement. Since then, that framing has been refined by the regulator itself.
The Federal Council has confirmed that the Ordinance does not prescribe XBRL as the only permissible format. However, where a company does not publish genuinely machine-readable information, it may currently explain objectively why this is not feasible. In practice, several companies have relied on this flexibility and published only a PDF.
A September 2026 market study reviewed 155 Swiss companies and found that 28, or 18.1%, had published an XBRL report. A further 39 companies provided an explanation for not doing so, while 88 appeared to provide neither an XBRL report nor a discoverable explanation. The study was based on manual research rather than an official register, so its results should be treated as indicative rather than as complete market statistics. Nevertheless, it provides the clearest evidence currently available that XBRL adoption remains at an early stage.
Recent Developments, the Paused Ordinance Revision and the Sustainable Business Conduct Act
A revision of the Climate Ordinance itself was under consultation between December 2024 and March 2025, proposing closer alignment with the latest international standards for climate reporting and minimum requirements for net-zero transition plans, particularly for financial companies. Entry into force was originally targeted for 1 January 2026.
That revision did not proceed on schedule. On 25 June 2025, the Federal Council paused it, pending the outcome of the broader sustainability-reporting reform and greater clarity on the EU’s simplification of its sustainability rules. The Federal Council stated that it would decide on the next steps once there was greater clarity on these developments, but no later than 1 January 2027.. The pause affects the planned threshold and transition-plan changes. It does not affect the existing Ordinance, which remains in force exactly as it has applied since 2024, including its human- and machine-readable format requirement.
In its place, the Federal Council published a preliminary draft Federal Act on Sustainable Business Conduct on 2 April 2026, its indirect counterproposal to the second Responsible Business Initiative. The draft closely follows post-Omnibus EU thresholds and narrows the scope of companies subject to sustainability reporting compared with current Swiss law, while adding supply-chain due diligence obligations. Consultation on the draft ran until 9 July 2026. The Federal Council has until 27 November 2026 to submit a final version to Parliament, after which the parliamentary process is expected to take at least 12 to 18 months. For companies currently in scope of the Swiss Climate Ordinance, the rules that apply today are likely to remain the operative rules for at least the next reporting cycle or two.
The pattern echoes what has played out at EU level, where Omnibus I’s scope reduction and delayed deadlines for CSRD have similarly narrowed and postponed elements of that directive. Compliance managers tracking both jurisdictions are, in effect, watching two parallel simplification processes move on comparable timelines.
How CFOUR Comply Supports Swiss Climate Ordinance Reporting
CFOUR Comply is built for XBRL-based reporting and supports Swiss Climate Ordinance filings alongside its existing coverage of ESEF and UKSEF. The platform converts an existing PDF annual report into the tagged, machine-readable format the Ordinance references, using automated tagging suggestions from its TagSense engine and Fujitsu-powered validation to check the result before submission.
PDF currently remains an acceptable format under comply-or-explain, so moving to XBRL is not a necessity for every company today. But companies that move early gain a head start on machine-readable reporting before any future revision removes that flexibility, and they avoid redoing the work later if the comply-or-explain allowance is eventually withdrawn. For a closer look at how the tagging and validation workflow actually runs, step by step, see our separate walkthrough.
CFOUR Comply’s roll-forward feature reuses a report’s tagging structure in later years once it’s been tagged once. Teams already familiar with XBRL as the structured data standard behind EU digital reporting will recognise the underlying tagging logic, and the same workspace can extend to ESEF or CSRD-adjacent tagging without a separate tool, using the same tagging and validation flow covered in our guide to ESEF reporting requirements and the iXBRL tagging process.
Conclusion
The Swiss Climate Ordinance has applied unchanged since 2024, and its format requirement remains more flexible than early commentary suggested, with PDF still accepted alongside XBRL under a comply-or-explain approach. A planned tightening of the rules has been paused until at least 2027, replaced for now by a broader legislative process still working through consultation. That uncertainty is not a reason to wait, since a paused revision can resume, and companies that already report in XBRL will find themselves better prepared.
