The EU Corporate Sustainability Reporting Directive (CSRD) requires certain companies to publish environmental, social and governance information against common standards, the ESRS. Its scope was cut back sharply in 2026. This is what applies today, and what it means for a Swiss company.
What the Omnibus I Directive changed
The Omnibus I Directive, published in the Official Journal of the EU on 26 February 2026, raises the CSRD thresholds. It now covers EU companies with more than 1,000 employees and net turnover above EUR 450 million. Listed SMEs fall out of scope. Member States have until 19 March 2027 to transpose the changes.
The timetable had already been pushed back in 2025: second-wave companies publish their first report in 2028, covering the 2027 financial year.
Double materiality
The CSRD rests on double materiality. A company reports on two things: how sustainability matters affect its financial performance, and how its activities affect the environment and society.
Swiss groups in direct scope
A group whose ultimate parent is outside the EU is in scope if it generates more than EUR 450 million of turnover in the EU in two consecutive financial years and has an EU subsidiary or branch with turnover above EUR 200 million. Only large Swiss groups are affected.
Everyone else, through their customers
Most Swiss companies will never fall under the CSRD. Their European customers who do, however, must document their value chain, and they ask their suppliers for figures, starting with the carbon footprint. For companies with fewer than 1,000 employees, the Omnibus I Directive limits such requests to the content of a simplified voluntary standard.
In Switzerland
Swiss law already requires a report on non-financial matters (Art. 964a to 964c of the Code of Obligations) from public-interest companies with at least 500 full-time positions and a balance sheet above CHF 20 million or turnover above CHF 40 million. Since 1 January 2024, a Federal Council ordinance has governed the climate section of that report.
On 1 April 2026, the Federal Council opened a consultation on a draft aligned with the Omnibus I Directive, and going no further: a sustainability report for companies with more than 1,000 full-time positions and turnover above CHF 450 million. The consultation closed on 9 July 2026. No date of entry into force has been set.
The key point
Few Swiss companies will publish a CSRD report. Many, however, will have to give a reporting customer a reliable carbon figure. For an SME, that is where it matters.
Sources: Omnibus I Directive, Official Journal of the EU, 26 February 2026; Federal Council, draft opened for consultation on 1 April 2026; Swiss Code of Obligations, Art. 964a to 964c.