Ordonnance sur les devoirs de diligence et de transparence en matière de minerais et de métaux provenant de zones de conflit et en matière de travail des enfants (DDTrO / VSoTr), RS 221.433; Code of Obligations Art. 964j–964l

Switzerland is consulting on amendments to the Code of Obligations and the Ordinance on Climate Disclosures that would replace the current TCFD comply-or-explain regime with mandatory disclosures using either ISSB Standards (with additional GRI-style information) or ESRS, broaden the scope to more companies and require assurance from year one.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Proposed Code amendments would apply two years after the legislative process concludes

Covered entities

Current rules apply to listed entities (other than those below CHF 450,000 balance sheet, CHF 900,000 revenue and 10 full-time positions) and non-listed companies above 500 employees, CHF 20m balance sheet and CHF 40m turnover. Proposed amendments would extend to entities exceeding two of: CHF 25m balance sheet, CHF 50m turnover, 250 average annual full-time employees over two consecutive years. Subsidiaries can be exempt where covered by an equivalent parent report

Directive requiring large EU and non-EU companies to identify, prevent, and remedy adverse human rights and environmental impacts in their operations and value chains, and to adopt a climate transition plan. Scope and timelines were revised by the 2025 Omnibus package and Directive (EU) 2026/470.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2027. First wave of in-scope companies covered from 2028.

Covered entities

Large EU and non-EU companies meeting employee and turnover thresholds (revised by 2025 Omnibus and Directive (EU) 2026/470).

Companies in scope must identify, prevent, and remediate human rights and environmental risks in their own operations and direct suppliers, with risk-based duties extending to indirect suppliers when substantiated knowledge arises. BAFA monitors compliance, can issue orders, and impose fines up to EUR 8 million or 2 percent of average annual turnover (where turnover exceeds EUR 400 million).

Enforcement

Mandatory

Effective date

1 January 2023 (companies with 3,000+ employees in Germany); 1 January 2024 (1,000+ employees in Germany)

Covered entities

Companies with their head office, principal place of business, administrative seat, or registered branch in Germany and at least 1,000 employees in Germany (3,000+ in 2023). Includes German branches of foreign companies.

Covered enterprises must conduct human rights and decent working conditions due diligence aligned with the OECD Guidelines, publish an annual account of their efforts by 30 June, and respond in writing within three weeks to public information requests. The Consumer Authority supervises through guidance, decisions, and enforcement penalties.

Enforcement

Mandatory

Effective date

1 July 2022; first annual due diligence accounts due by 30 June 2023

Covered entities

Larger Norwegian enterprises and foreign enterprises selling goods or services in Norway that are tax-liable in Norway. Companies must meet two of three thresholds: NOK 70 million sales revenue, NOK 35 million balance sheet total, 50 FTE employees.

In-scope parent and ordering companies must establish, publish, and effectively implement a vigilance plan covering risk mapping, supplier and subcontractor assessment, mitigation actions, an alert mechanism, and a monitoring scheme addressing human rights, health and safety, and environmental harm across the group and established business relationships. Any party with standing can give formal notice and, after three months of non-compliance, seek a court injunction and damages.

Enforcement

Mandatory

Effective date

27 March 2017; first vigilance plans required for FY2017

Covered entities

French-headquartered companies that, for two consecutive years, employ at least 5,000 employees in France (parent and direct/indirect subsidiaries) or at least 10,000 employees worldwide.

Covered companies would have to investigate whether child labour exists in their supply chains, adopt a plan of action where reasonable suspicion arises, and submit a one-time declaration of due diligence. Sanctions would include administrative fines and, on repeat offences, criminal liability for directors.

Enforcement

Mandatory

Effective date

Not yet in force as of 1 May 2026; original target of 1 January 2022 lapsed

Covered entities

Companies that sell goods or services to Dutch end-users, regardless of where they are established. Implementing decree was to set thresholds and exemptions.