6.2 Reporting Scenarios Based on Geographical Scope

SIX-listed companies have various disclosure obligations depending on where the company has its registered office and conducts its business and whether it is also listed on another stock exchange. There are four possible scenarios:

1. SIX-listed companies operating in Switzerland: Most SIX-listed Swiss companies are legally required to report on various non-financial matters. Similarly, companies that do not fall within the scope of Art. 964 CO need to be prepared to answer any non-financial information requests from other stakeholders in their supply chains, such as clients or financial institutions (e.g., insurers or banks). It is therefore in these companies’ best interests to report on material non-financial matters that they have identified in their stakeholder materiality assessment.

2. SIX-listed companies operating in the EU: SIX-listed companies operating in the EU may need to comply with the CSRD and apply the ESRS issued by the EFRAG. 

3. SIX-listed companies with dual listing in the US: In March 2024, the SEC approved the rules for the disclosure of climate-related information. Public companies listed on a US stock exchange will need to comply with these rules following their publication. The rules will be applicable from the 2025 financial year.

4. SIX-listed companies operating in other countries: The ISSB released two standards on general sustainability and climate reporting in June 2023 (IFRS S1 and IFRS S2). The standards are aligned with the TCFD recommendations, but they cover wider jurisdictional requirements. 

Ultimately, it is up to the individual jurisdiction to decide whether to mandate the use of the IFRS S1 and S2 disclosure standards. The UK, for example, has confirmed its adoption of the standards in principle, but the form and nature of their application are yet to be determined.¹ In the UK, the TCFD is already mandatory² for listed companies, banks, and insurers with more than 500 employees. Also obliged to disclose will be UK-based Alternative Investment Market (AIM) companies with 500 or more employees, limited liability partnerships (LLPs) with 500 or more employees and sales revenue of more than GBP 500 million, and non-listed companies with 500 or more employees and sales revenue of more than GBP 500 million. 

As the regulatory landscape for the disclosure of non-financial information is currently being shaped in many countries, companies will need to carefully observe what regulations and standards the different countries choose to adopt – whether it will be the CSRD in the EU, the IFRS S1 and S2 of the ISSB, or the SEC’s climate disclosure requirements.