Author : Earth Action team
The Swiss Federal Council opened a public consultation on 1 April 2026 on the Federal Act on Sustainable Corporate Governance, known as the Corporate Sustainability Act (CSA). For companies operating in Switzerland, this marks the beginning of a regulatory shift that will reshape how environmental and social performance is measured, managed, and disclosed.
The law is not yet final. But the direction is clear, and for the companies it will affect, the time to prepare is now.
What the law proposes
The CSA introduces a two-tier system aligned with EU frameworks. Around 100 large Swiss companies exceeding 1,000 employees and CHF 450 million in annual revenue will be required to publish annual sustainability reports covering environmental impact, human rights, and governance. A stricter due diligence tier applies to the approximately 30 largest Swiss companies above 5,000 employees and CHF 1.5 billion in revenue, requiring them to actively identify, assess, and address negative impacts across their full value chain, establish a formal due diligence strategy, and face potential fines of up to 3% of global turnover for non-compliance.
The law is deliberately designed to mirror the EU’s Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), ensuring Swiss companies remain on a level playing field with their European counterparts.
The timeline: further than it looks, closer than it feels
The consultation runs until July 2026. After that, the Federal Council will revise the draft, submit it to Parliament, and a referendum remains possible. Add a two-year transition period once the law passes, and mandatory compliance is realistically a 2028 or 2029 story.
That may sound distant. It is not.
Building the data infrastructure that a credible sustainability disclosure requires takes time. Mapping your value chain, collecting primary emissions data from suppliers, conducting product-level life cycle assessments, and establishing repeatable annual tracking processes: none of this happens in a few months. Companies that wait for the law to be finalised before starting will find themselves building under pressure, with auditors already at the door.
A useful reference point is the EU’s own experience. The largest EU companies, Wave 1 under CSRD, are already reporting. While the EU has since delayed and scaled back requirements for smaller companies under the Omnibus package, the direction of travel has not changed: environmental data across full value chains is becoming a baseline expectation, not a voluntary commitment. Switzerland is following the same path, and the CSA is designed to stay aligned with wherever the EU lands.
Not just a question for large companies
One of the most important and frequently missed implications of the CSA is what it means for companies that fall below the thresholds.
The due diligence obligations placed on large companies require them to examine the environmental and human rights performance of their suppliers and business partners. That means suppliers, subcontractors, and partners who are not themselves in scope will increasingly receive requests for emissions data, environmental impact assessments, and evidence of responsible sourcing practices from the large companies they work with.
This dynamic is already visible in Switzerland through CSRD: Swiss companies that supply into the EU market are already being asked by their European clients to provide Scope 3 data, LCA results, and supplier questionnaires. The CSA will replicate this effect domestically. If your customers include large Swiss companies, your sustainability data will become part of their compliance picture, whether or not the law applies to you directly.
The real question: do you have the data?
The challenge most companies face is not writing a sustainability report. It is having the underlying numbers to populate one credibly.
Most corporate carbon footprints today rely on spend-based estimates for Scope 3 emissions, using average economic factors rather than measured physical data. These are useful for a first assessment, but they are not what auditors will accept, and they are not precise enough to drive meaningful action. The shift to primary, activity-based data is coming, and building that foundation takes a structured programme of work.
Beyond Scope 3, the CSA’s due diligence requirements push companies toward product-level impact data. Knowing your corporate carbon footprint is not sufficient if you cannot show which materials, suppliers, or product lines carry the highest environmental risk. That requires life cycle assessment at scale, supply chain hotspotting, and, for companies with significant packaging or material flows, plastic leakage assessment.
While the CSA does not explicitly require Scope 3 reporting, its obligation to cover impacts across the full value chain and conduct due diligence effectively makes Scope 3 data unavoidable in practice.
It is tempting to treat this as a reporting exercise. That would be a mistake. In most industries, Scope 3 represents the majority of total impact, often 70% to 90%. Companies that invest early in understanding it are not just preparing for compliance; they are gaining visibility into supply chain risks, cost drivers, and product-level exposure that directly affect margins and resilience. As large Swiss and European companies push data requirements down their value chains, this visibility is quickly becoming a commercial necessity, not a nice-to-have.
This is where materiality and risk-based prioritisation matter. Not all Scope 3 categories carry equal weight, and not all data needs the same level of precision from day one. A pragmatic approach starts with identifying hotspots: the suppliers, materials, or product lines that drive the majority of impact – and focusing effort there. This allows companies to balance cost and impact, build robust data where it matters most, and align with regulatory expectations that increasingly emphasise material risks over exhaustive but low-value reporting.
The practical questions to ask today are straightforward. Do you know the actual environmental impact of your key products and materials, based on physical data rather than financial proxies? Is that data collected in a structured, repeatable way, or does it live in a one-off study? Could your methodology withstand third-party audit? And do you have a governance structure in place to update and track these metrics year on year?
For most Swiss companies in scope, the honest answer to at least some of these questions is no. That is not a criticism: this infrastructure does not yet exist in many organisations. But it needs to be built, and the window to build it thoughtfully, rather than reactively, is open right now.
What being ready actually looks like
Readiness is a progression, not a switch. It starts with understanding where your environmental impact actually sits: which materials, which suppliers, which product categories. From there, it moves to quantifying that impact with science-based methodologies, setting targets, and implementing the data systems that make annual tracking possible without starting from scratch each year.
Companies that are genuinely ready have moved from estimates to primary data, from one-off studies to annual tracking tools, and from internal assumptions to third-party validated numbers. That is a multi-year journey, which is exactly why 2026 is the right time to begin.
EA’s role in this
At Earth Action, we support companies across the full sustainability journey, including report writing. But what sets us apart is the scientific rigour we bring to building the underlying data.
We calculate product-level carbon footprints and life cycle assessments, model Scope 3 emissions from physical activity data, assess plastic leakage across value chains, and develop the tools that allow companies to update and track these metrics each year. We have done this for watchmakers, food and packaging companies, construction groups, and textile and apparel brands across Switzerland and beyond, including companies that will themselves be subject to the CSA.
If you are asking whether your organisation is ready, we are happy to help you find out. A readiness conversation costs nothing and tends to clarify a great deal.
The companies that will navigate this law with confidence are not the ones who prepare the best report. They are the ones who built the best data. That work starts now.