Swiss CO 964a-l
Swiss Code of Obligations art. 964a-964l, DDTrO (SR 221.433) and Climate Disclosure Ordinance (SR 221.434)
Topic : ESG disclosure · Level : National
Today
In force; draft NUFG act consulted 2 Apr-9 Jul 2026, Federal Council dispatch due end Nov 2026; climate ordinance revision paused.
Summary
Swiss rules on non-financial reporting, climate reporting and due diligence for conflict minerals and child labour. A draft act consulted in 2026 would align with the EU Omnibus: reporting above 1,000 FTE and CHF 450m, due diligence above 5,000 FTE.
Who is concerned
- Turnover
- Reporting: >CHF 40m sales or CHF 20m balance
- Employees
- Reporting: >=500 FTE (public interest)
- Listed company
- cotées et non cotées
- Sectors
- All sectors
- 3TG minerals and metals
- Triggering activities
- Swiss public-interest company (reporting)
- Importing/processing 3TG above thresholds
- Products with child labour suspicion
- Extraterritorial reach
- Yes
Due diligence on conflict minerals and child labour covers foreign suppliers and smelters.
- Examples
- Swiss listed group sourcing electronics in China
- Swiss watchmaker importing gold and tin
What the law requires
- Publish an annual report on environment, social, human rights and anti-corruption matters
- Report on climate in line with TCFD (climate ordinance)
- Apply supply-chain due diligence and audit for conflict minerals and child labour
- Report annually on due diligence, approved by the board
Penalties
Fine up to CHF 100,000 for false or omitted reports (CP art. 325ter); up to CHF 50,000 if negligent.
What this changes for a supplier in China
Swiss buyers of 3TG metals and consumer goods ask Chinese suppliers for smelter lists and child-labour checks; reporting scope may narrow from 2028.
Expected evidence
- Smelter list (CMRT)
- Age verification and child labour policy
- Country of origin of minerals
Tiers : Tier 1-N