Sustainability Reporting Trends for Swiss SMEs
What Swiss SMEs need to know about evolving sustainability reporting requirements and how to prepare for the changing regulatory landscape.
The sustainability reporting landscape for Swiss SMEs is changing fast. What was voluntary in 2024 is becoming expected in 2026 — and potentially mandatory by 2028. Here is what is driving the change and how to prepare.
The CSRD Ripple Effect
The EU's Corporate Sustainability Reporting Directive (CSRD) directly applies to large companies with 250+ employees. But its impact cascades down the supply chain. CSRD requires large companies to report Scope 3 emissions — which includes everything their suppliers produce, transport, and deliver. This means large companies are now sending sustainability questionnaires to their SME suppliers.
In Switzerland, this effect is amplified because Swiss exporters sell heavily into the EU market. A Swiss SME supplying parts to a German manufacturer subject to CSRD will receive data requests. The question is not whether, but when.
Key Regulatory Milestones
| Date | Event | Impact on SMEs |
|---|---|---|
| Jan 2024 | Swiss Art. 964a OR in force | Companies with 500+ employees must report (including Scope 3) |
| Jul 2025 | EFRAG VSME adopted as EU recommendation | VSME becomes the standard framework for SME sustainability data |
| Jun 2026 | EU Value Chain Cap (expected) | Large companies can request max VSME-level data from SME suppliers |
| 2026-2027 | Swiss revision of Art. 964a (under consultation) | Reporting threshold may drop to 250 employees, affecting ~3,500 companies |
| 2028 | CSRD fully phased in for all EU large companies | Maximum supply chain data pressure on SME suppliers |
Five Trends Shaping SME Reporting
1. VSME as the De-Facto Standard
The EU Value Chain Cap will make the VSME data points the maximum that large companies can demand from SME suppliers. This transforms VSME from a voluntary framework into the industry standard for supply chain sustainability data. SMEs that prepare a VSME declaration now will have a ready answer when the requests arrive.
2. Digital and Machine-Readable Reporting
The European Single Access Point (ESAP) will centralise sustainability data across Europe. While SME data is not required to be on ESAP, the trend toward structured, digital reporting means PDFs alone may not suffice long-term. EFRAG's XBRL taxonomy for VSME is a signal that machine-readable formats are coming.
3. Supply Chain Due Diligence Laws
Multiple laws are pushing sustainability requirements down supply chains:
- Germany: Lieferkettensorgfaltspflichtengesetz (LkSG) — companies with 1,000+ employees must ensure human rights and environmental due diligence across suppliers
- EU: Corporate Sustainability Due Diligence Directive (CS3D) — broader scope, expected to apply from 2027
- Switzerland: Art. 964j-l OR — due diligence obligations for conflict minerals and child labour
Each of these laws creates data requests that flow to SME suppliers.
4. Climate Risk in Bank Lending
Swiss financial institutions are integrating climate risk into credit decisions. The Swiss Bankers Association ESG guidelines and FINMA circular on climate risks mean that banks increasingly ask SME borrowers about their emissions and sustainability practices. A VSME declaration provides a standardised answer.
5. Greenwashing Enforcement
The EU Green Claims Directive (expected 2026) will require companies to substantiate sustainability claims with verified data. SMEs that make environmental statements on their website or in marketing materials will need evidence. A VSME report provides that evidence base.
How to Prepare
- Complete your VSME Basic Module now. Establish a baseline before reporting becomes expected or required.
- Systematise data collection. Set up a simple process to archive energy bills, HR records, and waste invoices annually.
- Understand your supply chain exposure. If you supply to EU companies with 250+ employees, expect data requests within 12-18 months.
- Designate responsibility. Someone in your company (CEO, CFO, or operations manager) should own the sustainability reporting process.
- Keep evidence on file. Upload utility bills and source documents alongside your declaration for audit readiness.
Sources
QuickVSME Team • Sustainability Experts