Sustainability reporting is evolving rapidly – not just through new regulatory requirements, but also in terms of frameworks applied, governance practices, and assurance levels. To understand the current state of play, PwC conducted a benchmarking analysis of sustainability reports published by Swiss-listed entities, focusing on SMI and SMIM companies. The findings reveal a diverse and dynamic reporting landscape in Switzerland, with many companies already going beyond minimum compliance.
About the analysis
PwC reviewed the sustainability reports of all SMI and SMIM companies that had published their 2024 reports by the end of April 2025 – a total of 38 entities. The sample spans seven major industry sectors, enabling the identification of trends across a highly diversified set of companies and adding depth and reliability to the analysis.
Reporting frameworks: GRI dominates, ESRS on the rise
With the Corporate Sustainability Reporting Directive (CSRD) being in force for Wave 1 companies since the reporting period 2024, it is interesting to understand which sustainability frameworks are currently used by Swiss-listed entities. Based on PwC’s analysis, all but one company prepared a sustainability report in accordance with or with reference to GRI (97%). Notably, the vast majority of companies (95%) also report in line with the GHG Protocol and the TCFD frameworks. About one third of the companies already referred to the ESRS in their basis of preparation and, even though they apply the GRI standards in parallel, most of them have already structured their sustainability statements according to the ESRS. A large percentage of the other companies used the ESRS to complete their double materiality assessment (DMA).
Interestingly, we found that most companies report based on four or more frameworks, with the main combination being GHG, GRI, TCFD, and SASB. The IFRS Sustainability Disclosure Standards have not yet gained importance in the Swiss market, with only four companies using them.
PwC insights: Ten companies already refer to the ESRS standards in their basis of preparation and use them not only for preparing their DMA, but also for most other disclosures in their respective reports and to structure their sustainability statement. Most of these companies are Wave 2 companies using this as a “preparation” year, while still including a GRI content index in parallel.
Integration with annual reporting: a mixed picture
Sustainability reports are not systematically integrated within the annual report, which can lead to inconsistencies between separately published reports. While most entities either integrate their sustainability disclosures into the annual report or release them on the same date, only 33 out of 38 reports combined the voluntary disclosures with those required under the Swiss Code of Obligations in a single sustainability report.
Integration into the annual report:
PwC insights: Publishing a separate sustainability report, or even several sustainability reports, creates a risk of data inconsistencies across the different reports published by the entity. It can also make it more difficult for investors to access sustainability-related data. While a company’s annual report is usually easy to find, locating the sustainability report can be more challenging when it is published separately or when multiple reports are issued according to different standards or requirements.
Swiss requirements: broad uptake, but implementation varies
The Swiss Code of Obligations (CO 964a–l) sets out mandatory sustainability disclosure requirements. A large majority of companies (92%) explicitly referenced Articles 964a–c in their sustainability reporting. Notably, all SMI entities did so (100%), compared to 87% of SMIM companies.
Compliance with CO 964a–c:
However, only 68% of Swiss-listed companies included a reference table for the Swiss CO 964a-c disclosures, with substantial differences between SMI (93%) and SMIM (52%).
Reference tables for CO 964a–c:
Around two thirds of the reports also make a clear reference to the Swiss Climate Ordinance, with the same number of entities disclosing information about their transition plans, some of which are still in the process of being finalised and lack further details. Only one entity chose to use the ESRS E1 disclosures to comply with the Swiss Climate Ordinance.
A majority of the companies also fulfil the obligations in relation to Art. 964j–l via their consolidated sustainability report; only nine are completely missing the respective disclosures. For child labour, more than half of the companies reported for 2024 that they were in scope of the reporting on their due diligence efforts and hence provided the respective disclosures; for conflict minerals, this was limited to only three companies.
PwC insights: The Swiss reporting requirements are taken seriously by the SMI and SMIM companies, with a vast majority including a reference to CO 964a–c, and two thirds also referencing the Ordinance on Climate Disclosures, transition plans, or disclosures under CO 964j–l.
Double materiality: becoming the norm
The DMA (with a financial and impact materiality approach) is a requirement under ESRS when implementing CSRD, but is also expected for disclosures made in accordance with the Swiss CO 964a–c. We observed that for the reporting year 2024, a clear majority (89%) of the Swiss-listed entities had already prepared a double materiality assessment to identify which impacts, risks, and opportunities are relevant for reporting, mostly declaring that the DMA adhered to the requirements of the ESRS.
Adoption of double materiality:
PwC insights: Only a small minority of companies has not yet introduced a double materiality assessment, as required by both the CH and the EU legislation, with a number of them having completed it in the current reporting period.
Governance: binding votes on sustainability reports with room to expand
The Swiss legislation speaks of an approval of the sustainability report – this is interpreted by companies either as a binding or a consultative vote. We observed diversity in interpretation of the law in respect of a binding vote on the sustainability report. The majority of entities only requested a consultative vote for their sustainability report’s approval. Only 42% of Swiss-listed companies requested a binding vote for the approval of their sustainability reports during their respective AGMs – with no difference observed between SMI and SMIM companies, and with most companies continuing to apply the approach defined in the prior year.
Binding vote practice:
PwC insights: Despite critiscm raised by several stakeholders in the prior reporting period, many companies continued to only ask for a consultative vote on the sustainability report from their shareholders. Without any further communication from the regulator, we do not expect any significant market movement in this area in the coming years.
Assurance: a key trust factor
The majority of companies (87%) have already sought assurance over their sustainability disclosures. Most received limited assurance on certain KPIs (74%), a few obtained limited assurance over their entire sustainability report (5%), and some secured a mix of limited and reasonable assurance over some KPIs (5%).
However, there is a strong disparity between the SMI, where all companies obtained some level of assurance over their respective sustainability reports, and SMIM, where only 78% of the companies obtained third-party assurance.
Third-party assurance:
PwC insights: Third-party assurance helps build trust and provides confidence to stakeholders that a company is making meaningful progress towards its sustainability targets. This is particularly important in the context of increasing scrutiny and accusations of greenwashing. The high number of companies that sought voluntary assurance over their sustainability statements underlines this message.
Key takeaways and outlook
Our benchmarking analysis showed that most companies have already prepared a sustainability report – either integrated into their annual report or published separately. The GRI framework is the most commonly applied, and the majority of companies report using four or more standards. This multi-framework approach, among other factors, contributes to the wide variation in sustainability reporting practices in Switzerland. The analysis also revealed that while not all entities are fully prepared for a potential tightening of sustainability requirements, many are actively addressing the gaps and demonstrating considerable flexibility in adapting to the evolving market demands.
