7 Requirements for Net Zero Roadmaps

Authors:

• Julian Meitanis, Director, Audit / Corporate Sustainability Services, KPMG

• Silvan Jurt, Partner, Audit / Head Corporate Sustainability Services, KPMG

Last updated on 12 May, 2025

Introduction

Net zero is no longer a vision — it is a regulatory target. From 2025, Swiss companies are required to present roadmaps on how they intend to achieve this goal. The consultation on the Ordinance on Reporting on Climate-Related Issues (Climate Ordinance, ) contains corresponding adjustments to the net-zero roadmaps (previously known as the “transition plan” or “climate transition plan”).

Roadmaps serve as a strategic instrument for the long-term planning of the decarbonization of a company or financial institution. They include a GHG balance sheet (Scope 1 to 3), define science-based reduction targets, contain intermediate targets for 2030 and 2040 and, where possible, sector-specific targets for 2035 and 2045. A linear reduction path to 2050 is recommended. The roadmaps are supplemented by action plans, governance structures and information on negative emissions.

Framework and objectives

By ratifying the Paris Agreement, Switzerland has committed to reducing its greenhouse gas (GHG) emissions by 50% by 2030 compared to 1990 levels. In addition, the net-zero 2050 target will be enshrined in national law by the Climate Protection Act (CPA), which will enter into force in 2025. The law obliges the federal government to align the financial sector with climate targets and ensure its contribution to reducing emissions. 

The applicable law (Article 3 of KlimaVO) already requires a roadmap that is consistent with the Swiss climate goals. From 1 January 2025, the Ordinance to the Federal Act on Climate Protection Targets, Innovation and Strengthening Energy Security (Climate Protection Ordinance, CPO) specifies the minimum requirements for companies. In accordance with the mandate of the Federal Council, principle-based minimum requirements for financial companies are included in the Ordinance on Reporting on Climate-Related Issues. This extends the existing regulation while increasing the comparability and informative value of the reporting.

While the preparation of the roadmaps is generally voluntary, the CPA explicitly requires them for applications for state subsidies under Article 6 and for financial institutions as part of the reporting obligation under the revised Ordinance on Climate-Related Issues (Climate Ordinance). 

The term “transition plan” is replaced by “roadmap” in line with the Climate Protection Act; the two are treated as synonyms. Roadmaps describe the path to net zero by 2050, address in particular climate-related transition risks and contain emission targets, intermediate targets and measures to reduce emissions in operations and along the value chain. The CPO defines minimum requirements for net-zero roadmaps for companies in the real economy and the financial sector. As investments and financing contribute significantly to climate impact, specific requirements apply to the financial sector. 

The roadmap should be compatible with the Swiss climate targets in accordance with the KIG and cover all key business areas. Therefore, Scope 3 emissions, i.e. indirect emissions along the entire value chain, must also be taken into account.

The adjustments in the consultation take account of international developments, which means that the disbanding of the Task Force on Climate-Related Financial Disclosures (TCFD) 2023, the direct reference to the TCFD recommendations will no longer apply. Instead, the consultation now generally refers to international reporting standards, including the International Financial Reporting Standards (IFRS) International Sustainability Standard Board (ISSB) Standard S2, which takes climate-related risks and opportunities into account. The IFRS ISSB standard and the EU requirements through the European Sustainability Reporting Standard (ESRS) cover the central aspects of the TCFD recommendations [1]. The Transition Plan Taskforce (TPT), an organization that led to the development of a comprehensive set of roadmap disclosure materials through an integrative approach, was integrated into the IFRS ISSB organization in 2024. This provides the IFRS ISSB with sector-specific guidelines for the voluntary development of roadmaps.

The CPA stipulates that all companies must reach net zero by 2050. Some companies are already using voluntary standards such as the Science Based Targets Initiative (SBTi) or the Glasgow Financial Alliance for Net Zero (GFANZ) to define their net-zero strategies.

Companies must prepare to back up their climate targets with robust and credible roadmaps. ​As the Adidas case has shown, there is an increasing risk. In the case of Adidas, a German court ruled that the company can no longer claim to be climate-neutral by 2050. This statement was classified as misleading as it does not contain a concrete roadmap in the form of measures and timetables for emission reduction. The court emphasized the need for transparent and verifiable climate protection strategies.

Financial sector: Specific requirements

Companies in the financial sector must draw up roadmaps with scientifically sound, sector-specific reduction targets for GHG emissions. These should be differentiated by asset class, as options for action vary depending on the type of investment, such as real estate or equity portfolios. The reduction targets concern the group-wide business activities of the financed companies, regardless of the location of the emissions. Where possible, upstream and downstream emissions of the invested or financed companies should also be included. These new requirements increase the transparency and binding nature of net-zero strategies and strengthen the climate-friendly orientation of financial flows.

On the way to climate neutrality: The Swiss regulation on net-zero roadmaps

With the publication of the regulation on the creation of net-zero roadmaps for companies in January 2025, Switzerland is setting a new standard for corporate climate responsibility. The regulation specifies the Federal Council’s expectations of the private sector to reduce greenhouse gas emissions to net zero by 2050 at the latest. It provides a structured basis for creating consistent, verifiable and science-based net-zero roadmaps — a key building block for a company-specific climate strategy.

Objective and area of application

The regulation is aimed at all companies in Switzerland, regardless of sector or size, which wish to develop a roadmap to achieve net-zero emissions or are required to do so in response to political, regulatory or market requirements. The main objectives are to create transparency on climate targets and measures, to systematically reduce emissions and to compensate for remaining emissions using robust negative emissions technologies.

Structure and core elements of the net-zero roadmap

The regulation requires a comprehensive presentation of the company’s decarbonization strategy. An individual net-zero roadmap for companies may include the following features:

• Purposes
  The company’s motivation to achieve the net-zero target by 2050 at the latest and embedding it in an overarching sustainability strategy as well as the relevance of climate issues for the business model must be presented transparently.
• Definition of the target path
  A target year for achieving net zero must be set, with intermediate targets in 2030 and 2040, as well as recommended intermediate targets in five-year increments. The targets must be based on scientific principles and be compatible with the 1.5°C target of the Paris Agreement.
• Emission balance, control approach and system boundaries
  Companies must fully and comprehensibly balance their GHG emissions, including Scope 1 (direct), Scope 2 (indirect from electricity, heat and cold) and, where relevant, Scope 3 (upstream and downstream) emissions. Clear definition of the control approach as the basis for the system boundary.
• Reductions trajectory and action plan
  A detailed catalog of measures describes how emissions are gradually reduced within the defined system boundaries. Technological, organizational and procedural approaches must be presented.
• Role of negative emissions
  Only unavoidable residual emissions may be compensated — exclusively through recognized negative emission technologies (e.g. direct CO₂ capture and storage). A development plan for the offsetting of emissions that are difficult to avoid must be described and the scope of this offsetting must be limited and justified.
• Governance and responsibilities
  The roadmap must be anchored in the company’s organization. Responsibilities, internal control processes and the monitoring of progress must be defined in a binding manner.
• Transparency and communication
  Progress must be disclosed on a regular basis. External audits, for example by independent third parties or in accordance with standards such as SBTi, are recommended.

• Adjustments
  Regular updating of timetables and measures. 

   

Methodology and reference to international standards

The regulation is based on established international frameworks, in particular the Greenhouse Gas Protocol and ISO standards. It also allows the integration of industry-specific standards and leaves scope for innovative approaches, provided that they are documented transparently.

Time frame and implementation

Although the application of the regulation is voluntary, the federal government expects broad implementation, particularly among large companies and emission-intensive industries. The regulation recommends drawing up net-zero roadmaps by 2030 and starting to implement them early. Companies that develop a roadmap in accordance with this regulation make a substantial contribution to achieving Switzerland’s climate goals and strengthening their own resilience.

Conclusion

The new regulation on net-zero roadmaps makes climate transparency a corporate duty. Switzerland is thus creating an instrument for implementing its climate goals — and is demanding a realistic, verifiable path to decarbonization from the economy. Those who do not present a clear target for 2050 will come under pressure in the future, not only from a regulatory perspective, but also financially and reputationally. Companies that strategically anchor net-zero roadmaps at an early stage ensure regulatory compliance and strengthen their capital market capacity.