Sustainability reporting

Issuers who have made use of the opting in for their sustainability report have, inter alia, the following obligations: These issuers have to publish their report in accordance with a standard recognized by SIX Exchange Regulation within eight months of the balance sheet date and they have to make it available electronically for a period of five years. Furthermore, by opting in, the issuers voluntarily assume the enforcement concept of SIX Exchange Regulation. The review covers compliance with the corresponding provisions of the DCG and DRRO as well as compliance with the selected recognized reporting standard. SIX Exchange Regulation focuses primarily on how the issuer has defined the material reporting topics and enters into a dialogue with the issuer to ensure and improve the quality of the sustainability reports submitted.

Conditions

Through Art. 9 DCG in conjunction with Art. 9 Point 2.03 DRRO issuers have the opportunity, by means of an opting in, to inform SIX Exchange Regulation that they issue a sustainability report in accordance with an internationally recognised standard. The opting in is published on the page Sustainability reporting for the purpose of informing market participants.

Companies that have not made use of the opting in remain free to produce and publish a sustainability report without reporting this fact to SIX Exchange Regulation. It is also permissible to include certain sustainability topics in the annual report.

Issuers that decide to make use of the opting in within the meaning of Art. 9 DCG are obliged to produce the sustainability report in accordance with the chosen internationally recognised standard and to make it available electronically on their website within eight months of the balance sheet date for the annual financial statements for a period of five years.

Enforcement concept

Sustainability reports published by issuers after the reporting of the opting in are subject to  enforcement activities of SIX Exchange Regulation with regard to compliance with the provisions of the DCG and the DRRO. This enforcement activity focuses on compliance with the relevant provisions of the DCG and DRRO as well as on compliance with the selected internationally recognised standards[PDF]. Furthermore, the determination of the material reporting topics is critically reviewed. SIX Exchange Regulation enters into a dialogue with the issuer to ensure and improve the quality of the sustainability reports submitted. 

If the random review of the sustainability report does not reveal any indications which would justify a preliminary investigation by SIX Exchange Regulation, the issuer will be notified of that fact by means of a “Direct Comment Letter”. The “Direct Comment Letter” may also include recommendations for improving the quality of sustainability reporting. The delivery and the content of the “Direct Comment Letter” will not be communicated to the public.

If the review of the report raises any questions, the issuer will be invited by SIX Exchange Regulation to submit its responses in the course of a preliminary investigation. The delivery and the content of the preliminary investigation will not be communicated to the public. Generally, the submitted statement and any resulting findings will be discussed with the issuer. 

The findings of the preliminary investigation are communicated to the issuer in writing in the form of a “Comment Letter”. SIX Exchange Regulation distinguishes between recommended and expected improvements in the issuer’s future sustainability reporting. The expected improvements will be followed up in the next report. The delivery and content of the “Comment Letter” will not be disclosed to the public.

In addition, we refer to the monitoring and enforcement of regular reporting obligations.

Regulations

Entry into force date: Directives DCG

Directive Corporate Governance

Directive on Information relating to Corporate Governance

Entry into force date: Directives DRRO

Directive Regular Reporting Obligations

Directive on Regular Reporting Obligations for Issuers of Equity Securities, Bonds, Conversion Rights, Derivatives and Collective Investment Schemes