Complying with EmpCo and UWG requirements
Sustainability red flags
When green claims become legal risks
Companies and financial institutions make different sustainability claims, from net-zero commitments in their reports to climate-friendly products and investments. As scrutiny from regulators, investors and consumers increases, one question matters more than ever: how credible are these claims?
Until recently, these gaps were primarily a reputational risk. Today, they are increasingly becoming a legal and regulatory risk. With EmpCo in the EU (applies 27 September 2026) and Swiss UWG Art. 3(1)(x) (in force since 1 January 2025), vague or unsupported sustainability claims are now a legal risk. The BAFU enforcement guidance on climate claims (March 2026) further clarifies regulatory expectations and substantiation requirements for the Swiss market.
96% of companies with climate pledges exhibit at least one potential greenwashing risk indicator
What the new rules require
While sustainability claims can cover a broad range of topics, current regulatory developments are particularly focused on climate and environmental claims.
The challenge: compliance, credibility and clarity
Most organizations understand they need to comply with CSRD/ESRS, CO 964a–c, and other local disclosure requirements. The challenge lies in ensuring that sustainability disclosures and communications are compliant, credible and clearly communicated, particularly where climate and environmental claims are concerned.
Your sustainability disclosures need to:
- Meet regulators' compliance expectations
- Substantiate every claim with evidence
- Be clear, concise and strategically positioned
- Satisfy investors, stakeholders and ESG rating agencies
- Avoid greenwashing red flags
Our solution: the red flag assessment
We help organizations identify and address compliance risks in sustainability disclosures and communications before regulators, investors or competitors do, with a particular focus on climate and environmental claims.
Our approach combines three elements
We map all relevant frameworks (EmpCo, UWG, CSRD/ESRS, CO 964a–c and BAFU enforcement guidance on climate related claims etc.) against your sector, geography and sustainability claims. This establishes a clear compliance baseline.
Our experts conduct a detailed passage-by-passage review of your sustainability disclosures and communications, screening for:
- Legal and greenwashing risks associated with climate and environmental claims
- Unsupported or insufficiently substantiated statements
- Gaps in evidence, governance or transition planning
- Structural issues, including unclear target setting, performance reporting, value chain descriptions and unnecessary duplication
We classify findings by severity and provide practical, prioritized remediation recommendations to strengthen compliance, credibility and clarity.
Contact PwC Switzerland to discuss your specific needs.
We'll help you turn greenwashing red flags into compliance confidence.
Join our upcoming webinar on "The Impact of EmpCo and UWG: From disclosures to products" on 18 November 2026 from 10:00 - 11:00
Contact us
Rahel Blumer
Sofia Jaccard
Tina Minci