Legal | Tax | Compliance
Legal | Tax | Compliance
In 2025, reporting companies had to disclose their climate efforts for the first time for the 2024 financial year – based on the CCR webinar of May 27, 2025 with sustainserv and MME.
Reporting companies had to report on their climate efforts for the first time in 2025 for the 2024 financial year. This article is based on the related presentation at the CCR webinar on May 27, 2025 by sustainserv and MME.
The current legislation on climate reporting is based on the Swiss Code of Obligations (CO 964a ff.), the Climate Reporting Ordinance (under revision), the Climate and Innovation Act (CIE), the CO2 Act and international standards such as TCFD. Companies are obliged to disclose climate risks, CO2 targets, implementation measures and their effectiveness as well as relevant performance indicators. The so-called "comply-or-explain" approach currently still applies.
First climate reports for the 2024 financial year show the shift from marketing to legal documents has begun. Climate transition plans are still often superficial, interim targets are missing or postponed, and financial impacts are rarely clearly quantified. Proxy advisors sometimes set higher standards than the law. Nevertheless, approval at general meetings is high.
The integration of climate issues into governance structures is progressing. Initial examples show that the Board of Directors and Executive Board are explicitly describing climate governance. Recommendations include involving the finance department in risk assessments and transition planning as well as addressing the topic in committees such as the Audit Committee.
Companies are at different stages of development: From separate processes to full integration into Enterprise Risk Management (ERM). Long-term perspectives and the adaptation of existing risk definitions are central to forward-looking management.
Best practices show: Transparent presentation of assumptions, methodology and scenarios is crucial. Semi-quantitative assessments and allocation to transition or physical risks increase clarity. Financial bandwidths provide indications of the resilience of the business model.
Many companies are committed to the 2050 net-zero target, but interim targets and concrete transition plans are often still lacking. Recommendations are aimed at refining and coordinating these with investment planning and long-term strategy. Some companies are already quantifying investments to achieve the target.
Success factors include the transparent presentation of climate target achievement, linking risks with key performance indicators and linking remuneration and target achievement. Validated SBT targets and internal CO2 prices are becoming increasingly important.
Companies continue to develop their climate reporting depending on their level of maturity. Validation, transparency about assumptions and methodology, and greater cooperation between sustainability and finance departments are necessary. Goal: comparability and credibility of reporting.
New regulations are entering or have entered into force (e.g. KIG, KIV, UWG Art. 3 lit. x). The consultation on extended climate reporting has been completed and entry into force has been announced for 1.1.2026. The transition plans (roadmaps) of the real economy are already subject to minimum requirements under the CIG/CIA. The financial sector will be required to comply with broadly interpreted existing standards (OR 964b) and their specification in the Ordinance on Climate Reporting for its transition plans.
ESRS, ISSB, GRI and SBTi 2.0 are developing convergently. Companies can use ESRS E1 and IFRS S2 as a guide. These require concrete transition plans, scenario analyses and quantifiable targets. Linking national requirements with international standards facilitates further development.
Environmental disasters such as those in the recent past (floods or storms) show that physical risks are real and costly. Tools such as Correntics enable location-based risk analyses. Scenario analyses (IEA, IPCC, NGFS) help to assess transition and physical risks holistically.
The new version (expected to apply from 2027) places more focus on accountability and proof of progress. Requirements for Scope 3, verifiability, climate transition plans and carbon removal are increasing. Companies should carefully consider validation before 2027.
