Get to Know Switzerland's Corporate Sustainability Act (CSA)

On 1 April 2026, the Swiss Federal Council opened public consultation on the draft Federal Act on Sustainable Corporate Governance, known as the Corporate Sustainability Act, or CSA.

The draft is Switzerland's proposed response to two things happening simultaneously. First, the EU finalised its Omnibus I Directive on 26 February 2026, which significantly scaled back the scope of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), raising the CSRD threshold from 250 employees to 1,000 and pushing CSDDD obligations to 2029. Switzerland watched those changes closely before publishing its own proposal, and the CSA is explicitly calibrated to match the post-Omnibus EU position.

Second, a coalition of 90 Swiss civil organisations launched the Responsible Business Initiative 2.0 (RBI 2.0), a popular initiative that would introduce more expansive corporate accountability obligations. The Federal Council has proposed the CSA as an indirect counterproposal to the RBI 2.0, meaning Parliament would be asked to adopt the CSA and reject the RBI 2.0 as unnecessary. A national referendum remains possible before any final enactment. The consultation closes on 9 July 2026. Enactment is not likely before 2028 at the earliest, given the Parliamentary process and potential referendum that follows.

Who would be in scope

The CSA proposes two distinct tiers, mirroring the EU CSRD/CSDDD structure after Omnibus I.

1. Sustainability Reporting

Swiss companies with more than 1,000 employees globally and more than CHF 450 million in global annual turnover would be required to publish annual sustainability reports. Stock exchange listing is irrelevant; the thresholds are based on size alone, so unlisted private companies are included if they meet the criteria.

This is actually a narrowing of today's rules. Currently, approximately 230 Swiss companies are required to publish non-financial reports under Arts. 964a et seq. of the Swiss Code of Obligations (CO). The CSA would reduce that number to around 100, but with significantly stronger obligations for those who remain.

2. Supply Chain Due Diligence

The approximately 30 largest Swiss companies — those with more than 5,000 global employees and more than CHF 1.5 billion in global annual turnover — would face additional supply chain due diligence requirements on top of the full reporting obligations. This mirrors the post-Omnibus CSDDD threshold and applies to names in Swiss pharma, financial services, industrials, commodities, and insurance.

Swiss CSA reporting obligations

For companies in the reporting tier, the draft CSA is a meaningful step up from the current CO framework. The key changes:

ESRS becomes the required standard. Currently, Swiss non-financial reporters can choose their own framework: GRI, TCFD, or their own approach. Under the CSA, reporting must follow the European Sustainability Reporting Standards (ESRS) or an equivalent standard approved by the Federal Council. This is the same comprehensive standard now required across the EU under the CSRD, covering environmental, social, governance, and cross-cutting disclosures.

Double materiality assessment required. ESRS introduces a specific approach to materiality that differs from current Swiss practice. Companies must assess both impact materiality (how the company affects society and the environment) and financial materiality (how sustainability factors affect the company's own performance and prospects). Both lenses must be applied and documented.

Scope 3 emissions by GHG Protocol category. The ESRS climate standard (E1) requires Scope 3 emissions to be reported disaggregated by all relevant GHG Protocol categories, rather than as a single aggregate figure. This is one of the most operationally demanding requirements for companies that have not yet built category-level Scope 3 data collection. 

Board accountability and governance disclosures. Boards must demonstrate sustainability competence. Companies must disclose their sustainability policy, how sustainability outcomes are linked to executive compensation, the negative impacts of their business activities, corrective actions taken, and measurable KPIs.

Net-zero target by 2050. Environmental reporting must include a commitment to net-zero and a credible pathway.

Mandatory external audit. Unlike the current CO regime, where voluntary assurance is common but not required, the CSA mandates independent third-party assurance of sustainability reports from the first reporting year.

Swiss CSA due diligence obligations

For the approximately 30 largest Swiss companies, the obligations go further still. These companies would need to:

• Conduct a risk-based assessment of their global operations, including subsidiaries and supply chain partners, for actual or potential negative impacts on internationally recognised human rights and environmental standards
• Develop a formal due diligence strategy, a Code of Conduct, and a risk management system covering risk identification, assessment, treatment, and remediation
• Implement a reporting system and provide ongoing support to SME suppliers in meeting due diligence expectations
• Publish annual board-approved reports on their due diligence activities

The CSA also proposes civil liability for parent companies where a subsidiary causes damage and the parent's due diligence failures can be demonstrated—a provision that gives the framework teeth beyond reporting alone.

Enforcement: A meaningful step change

One of the most significant aspects of the draft CSA is the enforcement regime, which is substantially stronger than anything in Switzerland's current sustainability framework. A new government body, the Federal Audit and Sustainability Supervisory Authority (FASSA), would oversee compliance with both reporting and due diligence obligations. FASSA's proposed powers include:

• Administrative sanctions of up to 3% of global annual turnover for non-compliance
• Authority to confiscate profits obtained in breach of the CSA
• Exclusion from public contracts for up to five years
• Publication of enforcement decisions

Criminal penalties of up to CHF 100,000 would also apply for individuals who intentionally falsify reports or fail to meet filing obligations.

For the largest Swiss companies, a 3% global turnover penalty represents a material financial exposure, shifting sustainability compliance firmly into the risk conversation with legal and finance leadership.

What this means for companies not directly in scope

Even if your company falls below the thresholds, the CSA's effects will be felt through supply chains. The largest Swiss companies (due diligence tier) are required to assess and manage sustainability risks throughout their supply chains, which means they will need emissions data, human rights risk information, and ESG reporting from their key suppliers. Those data requests will arrive regardless of whether the supplier is formally in scope.

For companies supplying large Swiss manufacturers, retailers, or financial institutions: expect requests for Scope 1 and Scope 2 emissions data, energy consumption, waste and water figures, and information about your own supplier practices. Companies that can provide this data quickly and credibly will have a competitive advantage in supplier relationships. 

The EU alignment case

One of the CSA's stated objectives is to eliminate divergence between Swiss and EU sustainability obligations, and that has a practical upside for companies with cross-border operations. ESRS is required under both the EU CSRD and the proposed Swiss CSA. A company already producing CSRD-compliant disclosures for its EU-facing operations has a significant head start: the data infrastructure, materiality assessments, and reporting processes are largely transferable. The CSA removes a scenario where Swiss companies would need to maintain two separate reporting frameworks for Swiss and EU requirements. This matters particularly for Swiss-headquartered multinationals, Swiss subsidiaries of EU parent companies, and Swiss companies with major EU customers or investors. 

What to do now

The CSA is not yet law, but the direction is set; this legislation has Federal Council backing, it is explicitly calibrated to the EU framework, and the political environment in Switzerland favours alignment with international standards. Companies that wait for Parliamentary enactment before starting preparation will be building under time pressure.

Practical steps for companies likely to be in scope:

1. Assess your scope position now. Check whether your global headcount and global turnover exceed the reporting tier thresholds (>1,000 employees and >CHF 450m). If you're close to the boundary, understand that the calculation uses global figures.
2. Benchmark your current reporting against ESRS. If you're doing CO-based non-financial reporting or TCFD-style disclosures, conduct a gap analysis against the full ESRS framework. The gaps — particularly double materiality, disaggregated Scope 3, and assurance readiness — take time to close.
3. Start building Scope 3 data by GHG Protocol category. This is consistently the longest lead-time item for companies new to ESRS. Corporate carbon footprint platforms with Scope 3 reporting helps companies build category-level data collection systematically.
4. If you're in the due diligence tier, assess your supply chain risk exposure. Map which supply chain partners carry the greatest human rights and environmental risk, and begin documenting your assessment methodology.
5. Participate in the consultation if relevant. The consultation is open until 9 July 2026. Companies with material views on the draft provisions have an opportunity to shape the final law.

Track how Switzerland's CSA fits into the global regulatory landscape with Zevero's Climate Policy Tracker.