CO Art. 964j–964l · VSoTr · NUFG in consultation
Switzerland has its own supply chain regulation. It is simply quieter.
Since financial year 2023, due diligence and reporting duties on conflict minerals and child labour apply. Many SMEs qualify for an exemption – but only once they have assessed and documented it.
The indirect counter-proposal to the responsible business initiative introduced concrete duties through Articles 964j to 964l of the Code of Obligations and the ordinance on due diligence and transparency: a supply chain policy, traceability, a risk management plan and a report. For minerals and metals an external audit is added.
The second act is running now. After the second responsible business initiative was filed in May 2025, the Federal Council opened the consultation on a federal act on sustainable corporate governance in April 2026. How strictly Switzerland will regulate is open. That the topic returns is not.
Who is affected
- Companies importing or processing minerals or metals containing tin, tantalum, tungsten or gold from conflict-affected and high-risk areas, above the volume thresholds in the ordinance.
- Companies with reasonable suspicion of child labour in their products or services.
- SMEs may be exempt from the child labour assessment – but must assess and evidence the conditions themselves.
What is required
- Supply chain policy
- Set down in writing which standards apply to your chain.
- Traceability
- A system that documents origin along the chain.
- Risk management plan
- Identify and assess risks and derive measures from them.
- Annual risk assessment
- For child labour, against recognised indices, unless an exemption applies.
- Report
- Annual reporting; for minerals and metals additionally independently audited.
How SCRM covers it
Origin and commodity groups
Suppliers with country, commodity group and upstream supplier – the base of any traceability.
Documented exemption
“Not affected” is evidence too. Assessment, date and reasoning stay on record.
Risk assessment with history
Annual assessments versioned – you can show what you knew and when.
Reporting base
Analyses the report draws on, instead of a search through the mail archive.
Frequently asked
We are an SME – does this apply?
Possibly not. The ordinance provides exemptions for smaller companies and low import volumes. The exemption is not automatic: you must check the conditions and be able to document the outcome.
What changes with the NUFG?
That is open. The bill is in consultation and the Federal Council is watching the international environment. A regime that builds on existing duties while relieving SMEs is the likely direction.
Should we wait until the law is settled?
The data you need is the same in every variant: who supplies, from which country, which commodity group, which evidence. That base is useful regardless of the statute – customers ask for it anyway.
As of July 2026. The NUFG is in the legislative process. Not legal advice.