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 requires large public-interest companies to report on non-financial matters, with climate reporting based on the TCFD recommendations on a comply-or-explain basis. After the 2024 consultation, the Federal Council asked the FDJP to prepare simpler options. Its April 2026 NUFG consultation draft would require reports to follow a standard used in the EU (ESRS) or an equivalent standard recognized by the Federal Council, with limited assurance by an audit firm and supervision by the Federal Audit Oversight Authority. The explanatory report names IFRS Sustainability Disclosure Standards with GRI additions as a possible equivalent, but says equivalence is not yet clear.

Enforcement

Voluntary or under development

Effective date

Not yet specified. The NUFG draft leaves entry into force to the Federal Council, allows publication only once the popular initiative 'Für verantwortungsvolle Grossunternehmen' is withdrawn or rejected, and keeps prior law for financial years running at entry into force and those starting in the following two years

Covered entities

Current rules (Art. 964a CO): public-interest entities that, together with controlled entities, have at least 500 FTE on annual average and exceed CHF 20 million balance sheet total or CHF 40 million turnover, in two consecutive years; entities controlled by a reporting parent or one filing an equivalent foreign report are exempt. NUFG draft (Art. 9): Swiss companies that, with controlled entities, have more than 1,000 FTE and more than CHF 450 million worldwide turnover in two consecutive years, plus Swiss subsidiaries or branches of foreign groups with more than CHF 450 million Swiss turnover; the Federal Council estimates about 100 companies instead of about 200 today.

Switzerland operates advance disposal fee (vRG) schemes for electrical and electronic equipment, batteries, glass bottles and PET, run by industry organizations (SENS, SWICO, Inobat, PET-Recycling Schweiz) under federal ordinances. The Packaging Ordinance adopted in June 2026 replaces the beverage container rules: packaging must be minimized, suitable for recycling and use recycled content where feasible (from 2030); sellers of beverage cartons and single-use plastic packaging above the thresholds must take them back unless they finance an industry scheme (from 2031); and recycling rates of at least 70% for beverage cartons and 55% for single-use plastic packaging apply from 2032, with possible mandatory deposits if missed. Until then, collection of plastic packaging remains largely industry-led and voluntary.

Enforcement

Mandatory

Effective date

VREG in force since 1 July 1998, revised scope effective 1 January 2022; VVEA effective 1 January 2016, amended 1 August 2026; VerpV in force 1 January 2027, with advance disposal fee for glass packaging (Art. 8) from 1 January 2028, general packaging requirements (Art. 3) from 1 January 2030, subsidiary take-back duty for beverage cartons and single-use plastic packaging (Art. 4) from 1 January 2031, and minimum recycling rates (Art. 7) from 1 January 2032; battery and glass advance disposal fees in place since the 1990s

Covered entities

Manufacturers, importers and retailers of electrical and electronic equipment, batteries, glass and PET beverage containers placing products on the Swiss market. Under the VerpV: manufacturers and importers of glass packaging (extended beyond beverage containers from 2028); retailers and manufacturers placing filled beverage cartons or single-use plastic packaging on the market that exceed CHF 1 million turnover and 500 kg of packaging in two consecutive years (take-back duty from 2031 unless met through an industry organization); all retailers and manufacturers supplying filled packaging (design requirements from 2030).

Directive requiring very large EU and non-EU companies to identify, prevent and address adverse human rights and environmental impacts in their own operations, their subsidiaries' operations and their chains of activities. Omnibus I (Directive (EU) 2026/470) raised the thresholds, deleted the climate transition plan obligation, removed the EU-wide civil liability rule (liability now rests on national law), and capped fines at 3% of net worldwide turnover.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2028. National measures apply to all in-scope companies from 26 July 2029; Article 16 reporting applies for financial years starting on or after 1 January 2030.

Covered entities

EU companies with more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover, or ultimate parents of groups reaching those thresholds. Non-EU companies with more than EUR 1.5 billion net turnover in the EU in the financial year before the last. Separate thresholds apply to franchising and licensing groups (royalties above EUR 75 million plus turnover above EUR 275 million).

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.