PwC's Reporting Compliance Check

Your path to successfully implement the Swiss Non-Financial Reporting

What can be expected?

While the Swiss sustainability regulations already appear complex, they are still in the process of development. In 2022, the Federal Council expressed its intention to revise the legislation in order to align it more effectively with EU regulations, and a consultation draft is expected to be published by mid-2024. The European equivalent to the RBI is the Corporate Sustainable Reporting Directive, known as CSRD, which is considerably more intricate compared to the prevailing Swiss legislation. On 22 September 2023, the Federal Council has already announced the essential parameters that will be included in the consultation draft.

Reduced employee thresholds, from 500 to 250 employees
Assurance requirement on the sustainability information

These key parameters will expand the scope of companies required to report under the RBI, and will also establish clear standards for the quality of information that will be disclosed.

What needs to be clarified?

Swiss public interest companies, which also include financial institutions, are now obliged to adhere to the newly implemented non-financial reporting regulations as part of the Swiss Counterproposal to the Responsible Business Initiative (RBI-CP). These provisions have been incorporated into the Code of Obligations under articles 964a-964c.

Starting from fiscal year 2023, organisations are required to disclose a comprehensive set of information regarding their policies, implemented measures, main risks, and key performance indicators in five key thematic areas: environmental matters, social issues, employee-related matters, respect for human rights, and combatting corruption. Additionally, the reporting must also provide necessary insights into the business context by disclosing the business performance, result, state of the undertaking, and the impact of its activities on these non-financial matters.

The climate ordinance complements the RBI as of January 2024. Companies must additionally disclose detailed information on climate-related matters aligned with the TCFD/IFRS reporting framework. The Ordinance obliges companies to thoroughly report on their climate related risks and opportunities while setting up and disclosing a transition plan that details how the organisation will transition to a net-zero economy by 2050. Many companies will have to rethink their sustainability strategies to meet the new disclosure obligations. This includes tasks such as defining the roles and responsibilities of the board of directors and enhancing the overall sustainability governance.

Publicly listed companies and financial institutions such as asset managers, banks, re/insurances must disclose non-financial information starting with financial year 2023, if they fulfil the following criteria:

A workforce of at least 500 employees (will be adjusted to 250 employees)
and over two successive financial years (either solely or with domestic and foreign subsidiaries) either:
1. A balance-sheet total exceeding CHF 20 million, or
2. A turnover exceeding CHF 40 million.

For the first time, the board of directors will be directly responsible for the preparation and the signing of sustainability related information. Companies that fail to comply with the reporting obligations or disclosing incorrect information will expose themselves to fines up to 100’000 CHF and worse, reputational damage.

PwC can support your compliance readiness with the Swiss RBI

Regulatory review

Assess/measure your alignment to the mandatory disclosures

Maturity review

Evaluate the quality of reported data against industry standards

Double materiality assessment

Review your double materiality assessment

Reporting support

Guide you in your reporting journey and draft your report

Risk management

Review your internal controls and procedures concerning ESG risk management

Market insights

Understand how competitors and peers comply with the RBI-CP provisions

Alignment of policies and processes

Update your existing policies regarding the five mandatory reporting topics and draft new ones

Benefits for clients

PwC has a wealth of experience across various industries, allowing to offer tailored solutions and insights that consider the unique challenges of different sectors.

End-to-end solutions

PwC offers a wide range of sustainability linked services, from legal and tax consulting to advisory and strategy to audit services. This comprehensive portfolio allows clients to address multiple aspects of their business needs under one roof.

Climate disclosure and transition planning

PwC is recognised for its strong competency in sustainability reporting, including guiding companies through the process of developing effective reporting strategies that align with regulatory demands. Furthermore, PwC focuses on helping organisations to effectively convey their sustainability goals to stakeholders, ensuring optimal communication and transparency.

The revisions to the Code of Obligations will require many companies to either initiate or update their reporting practices. While implementing the RBI may present challenges, it also opens the door to several beneficial outcomes. Proactive companies can enhance their risk management systems, enhance their reputation, mitigate the risk of greenwashing, and gain access to additional investments for financing their green transformation. Nevertheless, it is crucial to acknowledge the complexities and attain a comprehensive understanding of the evolving ESG regulatory environment, as this will profoundly influence strategic decision-making across various domains.

Want to learn more about sustainability in tax and legal?

Visit our service page

Get in contact with us!

https://pages.pwc.ch/core-contact-page?form_id=7014L000000kkoNQAQ&lang=en&embed=true

{{contentList.dataService.numberHits}} {{contentList.dataService.numberHits == 1 ? 'result' : 'results'}}

Contact us

Dr. Antonios Koumbarakis

Partner, Sustainable Capital and Sustainability & Strategic Regulatory Leader, PwC Switzerland

+41 58 792 45 23

Craig Stevenson

Partner, Sustainability & Climate Change Leader, Advisory , PwC Switzerland

+41 78 975 08 62

Dr. Astrid Offenhammer

Director, Sustainability & Strategic Regulatory, PwC Switzerland

+41 78 696 32 11

Rahel Blumer

Manager, Sustainability & Strategic Regulatory, PwC Switzerland

+41 76 568 20 51