Switzerland’s first year of machine-readable climate reporting.
A new paper from Swiss firm mms solutions offers an early assessment of digital climate reporting in Switzerland, where, since financial year 2025, large public-interest entities have been required to publish climate-related information electronically and in machine-readable form under Article 964 of the Swiss Code of Obligations. Author Sacha Kälin reviewed 155 Swiss companies to see how the requirement is playing out in practice.
The research found that adoption is still at an early stage. Only around 18% of the companies analysed had published a machine-readable report, while more than half neither did so nor offered an explanation. A key reason, the paper suggests, is the framing of the rule itself: unlike the EU’s ESEF mandate, the Swiss ordinance deliberately avoids prescribing a format, referring only to “an internationally used electronic format that is machine-readable” and offering companies a “comply or explain” choice. Several firms cited exactly this looseness, uncertainty over which taxonomy to use, or whether one was even required, as their reason for sticking with PDF.
The paper reveals, however, remarkable voluntary efforts from Swiss corporates, even if it is early days.
Among those that did file, Inline XBRL was the de facto choice even without a mandate requiring it, and reports leaned overwhelmingly on the ESRS taxonomy (around 78%), with the IFRS Sustainability Disclosure Standards taxonomy accounting for most of the rest. But the paper also documents wide variation in tagging depth, from ten tagged concepts to nearly 150, and a handful of technically flawed filings, which together make automated, cross-company analysis difficult for now, undercutting one of the central purposes of machine-readable reporting. Without a central repository of filings (these reports are all on corporate websites) that can validate disclosure and enforce a range of business rules that provide consistency across disclosures this is not, as yet, all that surprising.
Swiss law seems to prefer to emphasise choice and corporate independence. Admirable, but the Swiss experience is a case study in what happens when a regulator mandates machine-readability without prescribing the specifics. Different taxonomies, different granularity, data that will be difficult to compare. It is a very useful reminder that effective digital reporting rules need to specify both the taxonomy and the scope of tagging, not just require that reporting be “machine-readable”. As the paper notes, Swiss early adopters will be well positioned for the EU’s forthcoming European Single Access Point and for a reporting environment in which AI systems can extract and analyse structured data with greater reliability than data drawn from PDFs.
Read the paper here (translated into English) or here (in the original German). Our sincere thanks go to Sacha Kälin and the team at mms for this very helpful piece of work.
