Switzerland’s Federal Act on Sustainable Corporate Governance: What It Means for Swiss and Global Companies

Switzerland entered the mandatory sustainability reporting era on April 1, 2026. The Swiss Federal Council’s proposed Federal Act on Sustainable Corporate Governance (CSA), also known as the Loi fédérale sur la gestion durable des entreprises (LDGE) in French and Bundesgesetz über die nachhaltige Unternehmensführung (NUFG) in German, creates binding ESRS-aligned reporting and due diligence requirements — and its reach extends well beyond Swiss-domiciled companies. Any organisation conducting business within Switzerland may also fall within scope.

What is the Swiss CSA?

The CSA is Switzerland’s legislative response to mounting pressure for corporate accountability on environmental and social issues. Rather than put a stricter citizens’ initiative — the Responsible Business Initiative 2.0 (RBI 2.0), backed by over 90 civil society organisations — to a popular vote, the Federal Council developed its own framework: one deliberately aligned with the EU’s post-Omnibus Corporate Sustainability Reporting Directive (CSRD), while standing as independent Swiss law.

The public consultation opened April 1, 2026. A final implementation date has not yet been confirmed, giving companies a preparation window before obligations become binding.

Two Thresholds, Two Sets of Obligations

The CSA creates two separate tiers of obligation — sustainability reporting and due diligence — each with its own threshold.

Sustainability reporting obligations apply to companies with:

• 1,000+ global employees AND CHF 450 million+ in annual revenue
• Must report to the European Sustainability Reporting Standards (ESRS) or an equivalent framework
• Reports subject to mandatory external audit
• Overseen by the new Federal Audit and Sustainability Supervisory Authority (FASSA)

Human rights and environmental due diligence obligations (aligned to the EU CSDDD) apply to companies with:

• 5,000+ global employees AND CHF 1.5 billion+ in annual revenue
• Risk-based supply chain verification across full upstream and downstream value chains
• Documented code of conduct
• Established risk management systems and remediation mechanisms
• Board-level annual reporting on due diligence findings

Who It Applies To: Swiss and Global Companies

The CSA’s scope is broader than a domestic Swiss regulation. The law applies to companies that “conduct business indirectly with Switzerland” — which means multinationals supplying Swiss companies, maintaining Swiss subsidiaries, or operating in Swiss financial markets may be captured regardless of where they are headquartered.

For Swiss-domiciled companies, the obligations are direct. For international companies, exposure is two-fold:

Direct scope: Multinationals that meet the employee and revenue thresholds and maintain Swiss business relationships may fall within the CSA’s reporting or due diligence requirements.

Supply chain cascading: Companies above the due diligence threshold must conduct risk assessments across their full value chain. Suppliers — including SMEs — working with in-scope companies will face indirect pressure to provide sustainability data, even if they fall below the CSA’s own thresholds.

For companies already building EU CSRD infrastructure, Switzerland’s ESRS alignment means the same methodology, data architecture, and assurance processes apply. A single integrated reporting framework can satisfy obligations in both jurisdictions.

How the CSA Aligns with EU CSRD

The Federal Council designed the CSA to mirror the EU’s post-Omnibus CSRD framework. This is strategically significant: companies already investing in ESRS-compliant reporting for EU obligations can apply the same disclosures, data infrastructure, and audit processes to meet Swiss requirements.

The CSA is not a copy of the CSRD. It is an independent Swiss law with its own thresholds, enforcement body (FASSA), and legislative timeline. But the substantive convergence on ESRS removes one of the most common compliance barriers — maintaining parallel, incompatible reporting frameworks across jurisdictions. Under the CSA, Swiss sustainability disclosures fully align with other European companies' reporting.

Swiss CSA Legislative Timeline

The Swiss Federal Act on Sustainable Corporate Governance (CSA) was launched in consultation on 1 April 2026. The consultation period will run through the summer of 2026, and enter Swiss Parliament for debate later in the year. If passed and approved, the CSA would likely enter into law in 2027 or 2028, which exact phase-in and reporting timelines currently pending.

What Companies Should Do Now

The consultation period opens a preparation window before final implementation. The right steps depend on where your organisation sits relative to the thresholds.

If you’re within scope and above the reporting threshold (1,000+ employees, CHF 450M+ revenue):

• Conduct a gap assessment against ESRS disclosure requirements
• Assess whether existing CSRD infrastructure covers Swiss entities and operations
• Conduct a materiality assessment process to identify your organisation's sustainability opportunities and risks (IROs)
• Engage auditors early — mandatory external assurance is a requirement, not an option

If you’re above the due diligence threshold (5,000+ employees, CHF 1.5B+ revenue):

• Map upstream and downstream value chains for human rights and environmental risks
• Document or develop a code of conduct to the standard the CSA will require
• Establish board-level reporting processes for due diligence findings

If you’re a supplier to an in-scope Swiss company:

• Expect sustainability data requests from customers conducting supply chain risk assessments
• Begin building the data infrastructure to respond — cascading due diligence obligations are a predictable supply chain pressure

A Pattern Emerging Across Jurisdictions

The Swiss CSA joins a growing body of national sustainability reporting laws converging around ESRS: the EU’s CSRD, the UK’s Sustainability Disclosure Standards (SDS), California’s SB 253 and SB 261, and now Switzerland. For multinationals, ESRS is becoming the de facto international baseline for corporate sustainability disclosure.

Companies that approach each new jurisdiction as a separate compliance exercise face compounding costs and fragmented data. Those building a unified, ESRS-aligned data and reporting infrastructure are positioning for a world where the question is not whether to report — but how efficiently.

The Window Is Open

The Swiss CSA is in consultation, not yet law. But its direction is clear: mandatory, audited, ESRS-aligned sustainability reporting with serious enforcement mechanisms. Swiss companies and global organisations with Swiss exposure have time to prepare — and for many, the CSRD groundwork they’ve already laid is directly transferable.

Switzerland's requirements sit alongside a rapidly changing set of European and international reporting regimes, including the EU's Omnibus I revisions to the CSRD. For the wider picture, see our guide to global ESG regulations.