NUFG draft: what SMEs as suppliers should know now

With the new Federal Act on Sustainable Corporate Governance (NUFG), the Federal Council wants to oblige large companies to exercise more due diligence and transparency. SMEs are not directly affected, but as suppliers they very much are. The draft therefore introduces a cap on data requests to smaller business partners. If you already structure your sustainability data according to a recognised standard today, you are prepared.

What it is about

The NUFG is the Federal Council's answer to the second Corporate Responsibility Initiative. It rejects the initiative and sets against it its own law, which closely follows the simplified EU rules (Omnibus package). The draft contains two core obligations:

• Due diligence for human rights and the environment: companies with more than 5,000 full-time positions and over CHF 1.5 billion in turnover should systematically identify risks in their activity chain and take measures. Around 30 companies would be affected.
• Sustainability reporting: companies with more than 1,000 full-time positions and over CHF 450 million in turnover report on environment, social matters, employee concerns, human rights and corruption (with external review). That would be around 100 companies, instead of around 200 today.

Who is affected and how

Directly obliged is only a small group of large companies. The Federal Council explicitly states that SMEs are not directly affected by either obligation.

Indirectly affected, however, are many Swiss SMEs: if you supply a company that has to report, you will receive questions on energy, emissions, working conditions or governance. This is exactly where the draft sets a limit:

• For the report (Art. 12 para. 4): from business partners with fewer than 1,000 full-time positions, only information may be requested that is customary in the sector and based on an "international, voluntary standard designated by the Federal Council".
• For due diligence (Art. 6 para. 4): from partners with fewer than 5,000 full-time positions, information may only be requested if it cannot be obtained otherwise.
• Duty of support (Art. 6 para. 2): the obliged companies are to provide appropriate support to SMEs in their activity chain.

Which standard is meant: VSME and VS

The draft law does not name a standard. It leaves the decision to the Federal Council. The European route is the obvious reference point: in the EU, companies subject to reporting may in future only request data from partners with up to 1,000 employees to the extent of a voluntary SME standard. This standard was previously called VSME (Voluntary Sustainability Reporting Standard for SMEs) and is now being given a legal anchor as "VS"; the EU Commission adopted the corresponding delegated act on 3 July 2026, which is still being reviewed by Parliament and the Council. In substance, the VS is largely built on the VSME. For you, this means: if you report under the VSME today, you are working with exactly the data model that is becoming the benchmark for supply chain requests in the EU and probably also in Switzerland. You can read about the change in our article From the VSME to the VS standard.

The challenge for SMEs

In most SMEs, nobody works on sustainability full time. The requests still arrive: in different formats, with different questions, and often at short notice. In addition, many companies only partly know their own supply chain. In our 2026 study, 57% of respondents named a lack of supply chain transparency as the biggest hurdle in ESG management. Full transparency is achieved by only 24% with their direct suppliers and by 2% in the tiers behind them.

_{n = 74, not representative; 30% of responses come from companies with more than 5,000 employees.}

And there is a risk that should be addressed openly: in its consultation response, the Swiss Trade Association (Schweizerischer Gewerbeverband) warns that large companies could reduce the number of their suppliers in order to cut the review effort.

The opportunity

It is precisely this risk that makes preparation valuable. When key customers review their supplier base, those who deliver reliable data without effort for the customer stay in the running. The cap in the draft helps here: instead of ten different questionnaires, a common denominator emerges. If you have prepared it cleanly once, you can use it several times, and you stand out from competitors who answer every request from scratch.

Prepared in five steps

1. Clarify whether you are affected: which customers are large enough for a reporting obligation (in Switzerland or in the EU)? Which requests have you already received?
2. Collect baseline data according to the VSME: energy, emissions (Scope 1 and 2), personnel, occupational safety, governance. The basic part of the VSME is a good starting point.
3. Close the gaps: add missing policies and evidence, for example a code of conduct or an environmental policy.
4. Provide the data: as a report, data sheet or public profile, so that customers can use it without follow-up questions.
5. Keep it current: update annually and track the development of the NUFG and the VS.

Checklist for getting started

• List of customers with more than 1,000 employees drawn up
• Previous ESG requests collected and evaluated
• Responsible person named internally
• Energy and emissions data for the last financial year available
• Key policies (code of conduct, environment, occupational safety) documented
• Decision made on how you share data with customers

How ZEROvia helps

Reporting under the VSME is the core of ZEROvia. Available today:

• Guided reporting: from the baseline assessment through the ESG self-assessment to the complete VSME report
• Answering customer requests: requests in any format answered with AI support using your own data, checked before sending
• Closing documentation gaps: with document templates directly in the platform
• ESG profile: easy to create and findable for AI searches. You decide which data is visible
• ZAIA and ESG glossary: work without in-depth sustainability knowledge

On our roadmap: the switch to the VS, as soon as the standard is available in its final version.

The platform is hosted in Switzerland; data protection follows DSG and DSGVO.

Next steps

Download NUFG factsheet (PDF)

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• Start your baseline assessment, find out in a few minutes where you stand
• Book a conversation. We show you how to answer your customers' requests efficiently

Sources

• Federal Council: New law on sustainable corporate governance strengthens protection for people and the environment, media release, 2 April 2026
• Federal Office of Justice: Preliminary draft NUFG and Explanatory report, 1 April 2026
• FDJP: Federal Act on Sustainable Corporate Governance, accessed 27 September 2026
• BDO Switzerland: NUFG: new Swiss law on sustainable corporate governance, 16 April 2026
• Swiss Trade Association: Consultation response on the NUFG, 6 July 2026
• ZEROvia: From the VSME to the VS standard, 14 July 2026
• ZEROvia: 2026 study, September 2026

This article provides an overview of the state of the legislative process and does not replace legal advice. Last updated: 27 September 2026.