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Switzerland-ISSBCurrent comply-or-explain regime remains in force: Arts. 964a–964c CO and the Ordinance on Climate Disclosures (SR 221.434, TCFD-based, in force 1 January 2024, unamended). The Federal Council took note of the 2024 CO consultation results on 21 March 2025 and paused the climate ordinance revision on 25 June 2025. On 1 April 2026 it opened consultation (until 9 July 2026) on a new Federal Act on Sustainable Corporate Governance (NUFG) that would replace the CO reporting rules; no dispatch to Parliament published as of 23 September 2026.

Local adoption of IFRS S1 / S2 (ISSB Standards)

Switzerland · Federal Council and Federal Assembly (legislative process), with FINMA and SIX Exchange Regulation supervising listed entities and FAOA setting assurance requirements

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.

Category
ISSB-aligned sustainability disclosure
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the Federal Council, allows publication only once the popular initiative 'Für verantwortungsvolle Grossunternehmen' is withdrawn or rejected, and keeps prior law for financial years running at entry into force and those starting in the following two years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.
Notes
Originally drawn from the IFRS Foundation jurisdictional snapshot (updated 12 June 2025); updated 2026-09-23 from Federal Office of Justice documents and Fedlex. The climate ordinance revision was in consultation from 6 December 2024 to 21 March 2025. NUFG Art. 11(6) gives the Federal Council an explicit mandate to set climate reporting rules, and the draft would repeal Arts. 964a–964c CO.

Sources

Related regulations

CH-DDTrO

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 · Federal Department of Justice and Police (FDJP) and the company's audit firm; civil/criminal liability via the Federal Department of Finance for false reporting
In force from 1 January 2022; first reports required for financial year 2023, published by mid-2024. A Federal Council consultation draft (NUFG, consultation 1 April to 9 July 2026) would move these duties into a new federal act; no dispatch to Parliament published as of 23 September 2026.

In-scope Swiss companies must operate a supply chain management system, traceability and risk management aligned with the OECD Due Diligence Guidance for minerals and the ILO-IOE child labour due diligence guidance, and publish an annual report. False or missing reports can trigger fines up to CHF 100,000 under Art. 325ter of the Swiss Criminal Code.

Enforcement
Mandatory
Effective date
1 January 2022; one-year transition meant first reporting period was FY2023
Covered entities
Companies with registered office, head office, or principal place of business in Switzerland that import or process tin, tantalum, tungsten, gold (3TG) above annual volume thresholds set in the DDTrO annex, and companies that offer products or services where there is reasonable suspicion of child labour. SMEs and low-risk companies are exempt under defined conditions.
Primary source ↗Verified 2026-09-23
In force; VREG amended 2022 to extend scope to all EEE. VVEA amendments in force 1 August 2026. New Packaging Ordinance (VerpV) adopted 24 June 2026, in force 1 January 2027 with phased duties to 2032.

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).
Primary source ↗Verified 2026-09-23
Effective. Group 1 has reported since financial years beginning 1 January 2025 and Group 2 since financial years beginning 1 July 2026. Treasury is consulting on changes to reduce reporting costs (closes 2 October 2026).

Australia has adopted ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory for entities within Chapter 2M of the Corporations Act and is phased in across three groups from 2025 to 2027. AASB S1 (general sustainability) is voluntary. ASIC administers the regime and has published guidance in RG 280.

Enforcement
AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.
Effective date
Financial years beginning on or after 1 January 2025 (Group 1), 1 July 2026 (Group 2) and 1 July 2027 (Group 3). AASB S2025-1 amendments apply to annual periods beginning on or after 1 January 2027, with early application permitted.
Covered entities
Entities that must prepare annual financial reports under Chapter 2M of the Corporations Act and meet a s292A threshold. Group 1: at least two of consolidated revenue of AUD 500m or more, consolidated gross assets of AUD 1bn or more, and 500 or more employees; or NGER registered corporations in groups that meet the s13(1)(a) NGER threshold. Group 2: at least two of revenue of AUD 200m or more, assets of AUD 500m or more, and 250 or more employees; all other NGER registered corporations; and registered schemes, RSEs and retail CCIVs with assets of AUD 5bn or more. Group 3: at least two of revenue of AUD 50m or more, assets of AUD 25m or more, and 100 or more employees.
UK-SRS

UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2)

United Kingdom · UK Government (Department for Business, Innovation, Science and Trade, renamed from DBT in July 2026) / FRC; FCA for listed-entity application
Final standards published 25 February 2026 for voluntary use; FCA consultation CP26/5 closed 20 March 2026; FCA policy statement expected autumn 2026 (not published as of 23 September 2026)

UK SRS S1 and S2 are the UK government's endorsed versions of IFRS S1 and S2, published on 25 February 2026 for voluntary use. Voluntary users can apply the Scope 3 and non-climate reliefs with no time limit. The FCA has consulted on listing rules that would make UK SRS S2 climate reporting mandatory for listed companies, with Scope 3 emissions and UK SRS S1 non-climate reporting on a comply-or-explain basis.

Enforcement
Voluntary at publication. FCA proposes mandatory UK SRS S2 for listed issuers (Scope 3 and broader sustainability on comply-or-explain).
Effective date
Voluntary use: no effective date (entities apply the standards when they choose). FCA proposal, subject to the final policy statement: rules in force 1 January 2027 for accounting periods beginning on or after 1 January 2027; using the transitional reliefs, Scope 3 reporting from periods beginning on or after 1 January 2028 and UK SRS S1 non-climate reporting from periods beginning on or after 1 January 2029.
Covered entities
Any entity (voluntary). The FCA proposal covers issuers in the commercial companies (UKLR 6), non-equity and non-voting equity shares (UKLR 16), transition (UKLR 22), secondary listing (UKLR 14) and depositary receipts (UKLR 15) categories. No mandate yet for unlisted companies.
Canada-CSDS

CSDS 1 and CSDS 2 – Canadian Sustainability Disclosure Standards

Canada · Canadian Sustainability Standards Board (CSSB), under FRAS Canada
Final standards published (voluntary); CSA mandatory rule paused since April 2025 (no resumption found); CSDS 2 GHG emissions amendments proposed April 2026

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. The standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025. In April 2026 the CSSB proposed CSDS 2 amendments matching the ISSB's IFRS S2 amendments: limiting Scope 3 Category 15 to financed emissions, allowing an industry classification other than GICS, and allowing other GHG measurement methods or GWP values where a jurisdictional authority or exchange requires them.

Enforcement
Voluntary
Effective date
Standards effective for annual reporting periods beginning on or after 1 January 2025, for entities that choose to apply them (with transition reliefs). Voluntary; no mandatory reporting date exists.
Covered entities
Any Canadian entity (voluntary). CSA paused work on mandatory rule citing global developments.
Japan-SSBJ

SSBJ Sustainability Disclosure Standards (Application, General, Climate)

Japan · Sustainability Standards Board of Japan (SSBJ)
Final standards published 5 March 2025; mandatory under the FSA's Cabinet Office Order amendment promulgated 20 February 2026, first cohort from the fiscal year ending March 2027

SSBJ published its Application, General and Climate Standards on 5 March 2025, and the SSBJ and ISSB confirm they are functionally aligned with IFRS S1 and S2. The FSA amended the Cabinet Office Order on Disclosure of Corporate Affairs on 20 February 2026 to require SSBJ-based disclosures in Annual Securities Reports for large Prime Market companies from the fiscal year ending March 2027, with third-party assurance one year later.

Enforcement
Mandatory for Tokyo Stock Exchange Prime Market companies, phased by market cap, through Annual Securities Reports under the Cabinet Office Order on Disclosure of Corporate Affairs. Voluntary for other entities.
Effective date
Voluntary for annual periods ending on or after 5 March 2025. Mandatory for Prime Market companies by average market cap (average of the last five fiscal year-ends): ¥3 trillion or more from the fiscal year ending March 2027; ¥1 trillion or more from the fiscal year ending March 2028; ¥500 billion or more from the fiscal year ending March 2029. Timing for other Prime Market companies to be decided later. Mandatory assurance starts one year after each cohort's first mandatory year.
Covered entities
Tokyo Stock Exchange Prime Market companies with average market capitalization of ¥500 billion or more, in three cohorts (¥3 trillion, ¥1 trillion, ¥500 billion). Timing for other Prime Market companies not yet set.