The Swiss Climate and Innovation Act enshrines the objective of reaching net greenhouse gas (GHG) neutrality in Swiss law. To reach net zero, the law defines two overarching measures: reducing emissions as much as possible, and counterbalancing the remaining emissions by using removals in Switzerland and abroad.

The law also sets indicative targets for the buildings, transport and industrial sectors: 100%, 100% and 90% respectively. It however does not provide indicative targets for other sectors. Furthermore, it requires of the federal and cantonal administrations to reach net GHG neutrality by 2040.

The Climate and Innovation Act codified intermediate climate targets for Switzerland. Between 2031 and 2040, GHG emissions must be reduced by at least 64% on average compared to 1990s levels, by 2040 by at least 75% and between 2041 and 2050 by at least 89% on average.

Switzerland also participates in the Nationally Determined Contributions (NDC) process under the Paris Agreement. Switzerland’s first NDC committed to an emissions reduction target of 50% by 2030, while the second NDC committed to a target of 65% by 2035. This target is not legally binding. The next round of NDCs will be submitted in 2030.

The Climate and Innovation Act sets an implicit carbon removal target of a maximum 11% of the GHG emission levels of 1990, which corresponds to about 7 MtCO₂.

Prior to the adoption of the Act, the Swiss National Long-Term Climate Strategy labelled CDR as necessary to reach net zero greenhouse gas (GHG) emissions by 2050. The strategy estimates that there is a need for CDR of 7 MtCO₂/year by 2050, which corresponds to the expected residual emissions of Switzerland in 2050. The volume is consistently referred to in other documents, including the CCS and CDR Roadmap.

Note: The emission reduction target foreseen in the Climate and Innovation Act can be partially met through emission reduction projects undertaken abroad, which are then attributed to Switzerland under the mechanisms set out in Article 6 of the Paris Agreement.

The long-term climate strategy, and later the Swiss CCS and CDR Roadmap, foresaw that the 7 MtCO₂ of annual residual emissions in 2050 should be compensated by removals. 2 Mt removals per year are expected to be achieved nationally, mostly through bioenergy with carbon capture and storage (BECCS), and 5 Mt are expected to come from CDR projects outside of Switzerland, predominantly direct air carbon capture and storage (DACCS). Conventional land-based removals are less favoured, owing to their lower permanence and higher risks of reversal.

Note: BECCS and DACCS are identified as the main CDR methods that will be used. However, official documents state that other CDR methods can be used, such as enhanced rock weathering and biochar. However, biochar’s use is not yet endorsed, with the Swiss government believing more research needs to be done to understand biochar’s long-term effects on soils and climate.

The Climate and Innovation Act states that, after 2050, removals through negative emission technologies should exceed the volume of gross GHG emissions in any given year. It makes however no mention of a quantified net negative target.

Biomass sustainability

The topic of biomass sustainability for BECCS and other biomass-based CDR is being looked at by the government. Research challenge 3 of the SWEET Call 2024, a funding call released by the Swiss Federal Office of Energy, aims to explore “the sustainable potential of Swiss biomass [and how it] can best contribute to the net-zero target by serving as a substitute for GHG-intensive materials, a source of renewable energy, and a provider of negative emissions”.

Mitigation deterrence

A certain share of emission reduction can take place through internationally traded mitigation outcomes (ITMOs) under Article 6 of the Paris Agreement. In the last CO₂ Ordinance, this share was of 25%. However, in the newest version of the Ordinance, this share was brought between 25 and 30%. This means that Switzerland can rely on substantial emission reductions undertaken abroad, instead of reducing its emissions domestically. This approach creates a risk of mitigation deterrence, as Swiss polluters have an option not to reduce their emissions.

Note: Mitigation deterrence is explained in a separate report by Carbon Gap.

Like-for-like principle

The Swiss government appears to have an ambivalent view of CDR’s role in Swiss climate policy. On the one hand, only permanent removals are planned to be used to compensate for residual emissions to reach net neutrality in 2050. On the other hand, both emission reduction, nature-based and permanent removals can be used to offset domestic fossil fuel emissions, in contradiction of the like-for-like principle.

In general, as detailed in its long-term climate strategy and the CCS and CDR Roadmap, the Swiss government plans to only rely on permanent removals to compensate for Swiss residual emissions. It made this decision based on nature-based removals having too high reversal risks.

However, stemming from the CO₂ Ordinance, fossil fuel producers and importers are obliged to offset a share of the emissions induced by their products through carbon offset projects and programmes (between 5 to 90%). These projects and programmes include traditional emission reduction projects, nature-based removals and permanent removals. Therefore, the like-for-like principle is not currently met.

Note: The like-for-like principle is a precondition to reach a state of durable net-zero, in which all fossil GHG emissions are compensated by durable removals.

Some monitoring, reporting and verification (MRV) rules have been set for emission reduction and carbon storage projects qualifying under the CO₂ Ordinance. Qualified projects and programmes are granted attestations which can be used as proof that the emissions were offset.

Validation and verification

A list of validators and verifiers (VVs) has been approved by the Federal Office of the Environment, both for projects in Switzerland and abroad. Each project and programme must be validated and verified before they can be granted attestations. VVs abroad must be agreed upon in bilateral agreements with host countries under Article 6.2 of the Paris Agreement.

Monitoring

During the validation process, applicants must produce a monitoring report that details how data will be collected. Attestations are then issued once emission reductions have been achieved. There is, however, no description of the monitoring process after attestations have been issued and after the lifetime of the project.

Reporting

Reporting requirements structure the validation and verification processes, and remain present throughout the monitoring of projects. These requirements are detailed in the documentation about carbon offsets projects and programmes.

While the attestations issued through the CO₂ Ordinance resemble a certification scheme, there is no proper certification mechanism in place, nor is one planned for the time being. Since Switzerland intends on using Article 6.4 of the Paris Agreement once it is operational, this framework would provide a global certification mechanism that could replace the need for a national MRV system.

Note: Regarding the interactions between Switzerland and the EU, it is unclear what Switzerland would do if CRCF scope is indefinitely restricted to the EU or the EEA.

Clear rules have been put in place for producers and importers of fossil fuels on how they can use carbon units, defined through the CO₂ Ordinance. However, these rules do not directly regulate environmental and climate claims.

Swiss law makes no mention of a legislation regulating environmental and climate claims, nor does it show signs to propose such legislation for now. Nonetheless, the Federal Act on Unfair Competition provides an early legal basis for procedural matters, especially about which institution is in charge of determining the lawfulness of a claim. There have also already been a few court cases where climate claims were contested and proven unlawful and the number of cases is growing.

The Swiss Nationally Determined Contribution (NDC) states that “Switzerland has included all categories of anthropogenic emissions or removals in its NDC.”

The Swiss Climate and Innovation Act clearly states that anthropogenic removals counting towards Swiss climate targets include both natural and technological sinks.

The use of Article 6 of the Paris Agreement is allowed by the Swiss government. Switzerland has already signed bilateral agreements with 13 countries under Article 6.2. It also undertook the first exchange of ITMOs under Article 6.2 with Thailand in 2023.

Together with Sweden, Switzerland is also pioneering the exchange of durable CDR under Article 6.2 as part of a memorandum of understanding signed in 2023. In 2024, Switzerland and Norway signed a declaration of intent to cooperate on CCS and CDR. The declaration also includes the piloting of the exchange of durable CDR under Article 6.2.

CO₂ transport and storage are only partially regulated in Swiss law. This absence of a comprehensive national framework creates a lot of legal uncertainties which need to be assessed on a case-by-case basis.

For now, regulation of any CO₂ pipeline and geological storage facility falls under the remit of Swiss cantons, as there is currently no constitutional basis for comprehensive regulation by the federal government. In the current setting, the federal government can only regulate specific projects that serve the interest of the whole country, as per Article 81 of the Swiss Constitution. This option is however unlikely to be used and competence will stay within cantons unless the Swiss Constitution is amended to provide competence for the development of legislation and technical regulations for CO₂ pipelines to a (new) federal authority. This process would take a long time and would be subject to a public vote (given that all amendments to the Constitution are subject to a mandatory referendum in Switzerland).

Moreover, there are no harmonised national safety requirements for geological CO₂ storage, processes for exploration of suitable sites, and framework conditions regarding authorisation and responsibility for the transport of CO₂ for storage abroad. There is no national liability framework for CO₂ storage either.

The Federal government has identified this lack of a harmonised legal framework as a key hurdle to address to reach the Swiss CCS and CDR goals. The fact that the “search for an appropriate general framework and national and international regulations required by CO₂ capture, use and storage technologies” is one of 13 priority research topics of the “mitigation” dimension of the Swiss 2025-2028 Environmental Research Masterplan suggests that the issue is taken seriously. Furthermore, Motion 24.4256 calls for the Swiss government to propose a legislative framework on CO₂ capture, transport and storage. As of November 2024, this motion has not yet been received by the Swiss government.

Regarding the London Protocol, which regulates sub-seabed geological storage of CO₂ and transboundary CO₂ transport in international marine environments, Switzerland ratified the amendment to Article 6 of the protocol in November 2023.

(a) Physical storage capacities

Geological storage

There is no complete assessment of geological storage capacities in Switzerland as of late 2024. A first study was conducted in 2010 and a mini pilot project is ongoing to test CO₂ injection underground.

The CDR and CCS Roadmap introduces a national exploration programme for geological CO₂ storage sites. A report was initially expected by 2023, but it has not yet been published as of November 2024.

The SWEET Call 2024 outlines research challenge 2 as identifying robust pathways to build and operate a Swiss carbon capture, use, transport and storage infrastructure.

Mineral and product storage

The DemoUpCarma research project aimed to demonstrate the technical feasibility of storing CO₂ in primary and recycled concrete. The project contributed to building a commercial value chain for several plants to store CO₂ in concrete, equating to roughly 700 tCO₂/year. While the project did not quantify the long-term potential of storage in concrete, the Swiss government estimated that about 2.5MtCO₂/year could be stored in concrete by 2050.

(b) Estimation of CO₂ storage needs

Clear estimates of CO₂ storage needs appear in the CCS and CDR Roadmap and the long-term climate strategy: by 2050, 7 MtCO₂ will be captured and removed yearly in Switzerland, and an additional 5 MtCO₂ is to be removed abroad. Out of the 7MtCO₂ captured and removed in Switzerland, only a share will be stored in Switzerland, in the order of 2 to 5 MtCO₂/year.

Cross-border cooperation

The DemoUpStorage project explores the potential of transporting and storing Swiss biogenic CO₂ in Icelandic basalt, alongside the potential to scale this pathway for CO₂ storage. DemoUpStorage also has a side project with the Northern Lights CO₂ storage project in Norway.

Furthermore, Switzerland has started cross-border cooperation on CDR with Norway, the Netherlands and Iceland of varying degrees of maturity and scope.

Sub-national action is being taken on CDR. For example, the City of Zürich will export CO₂ to Denmark as part of a collaboration with the Greensand project.

State support

State support for CO₂ transport and storage in Switzerland is confined to research and exploration projects at the moment.

Based on Article 6 of the Climate & Innovation Act, the Climate Protection Ordinance implements direct funding for the deployment of “novel” technologies and processes (including CDR and CCS) by companies to reduce, capture or remove their (hard-to-abate) emissions. However, this funding can probably not be used for infrastructure projects for CO₂ management such as CO₂ pipelines.

The permitting process for CO₂ infrastructure is not yet set out on a federal level, especially in those cases where the project is under cantonal competence, with all cantons having their own legal framework.

To address this lack of legal clarity, one of the measures introduced in the CDR and CCS Roadmap was to examine and develop new legal bases concerning the permitting of the construction and operation of capture plants, including transport and storage, to the extent allowed for within the competences of the federal government.

Various studies and sources have identified that there is some potential to deploy certain CDR methods within Switzerland and some additional assessments are underway. To date, no comprehensive assessment of all relevant CDR methods has been carried out.

A report by the Federal Council was published in March 2023 exploring the potential of soil carbon sequestration in Switzerland. However, due to a lack of data regarding the state of soils in the country, only approximations were made about the quantity of carbon stored in Swiss soil currently and their future potential.

The CCS and CDR Roadmap identifies the need to conduct studies to clarify the carbon sink potential of forests and timber.

A report by the Risk Dialogue Foundation (mandated by the Swiss government) estimated a total theoretical removal potential of about 6 MtCO₂/year in Switzerland (including forest and soil carbon sequestration, biochar, BECCS, DACCS and enhanced rock weathering). This theoretical potential took into account potential limits to the use of biomass, alongside constraints associated with sustainable land use. It also found that there is limited potential to increase the capacity of natural carbon sinks in Switzerland due to the country’s small size, high population density and relatively high forest cover.

Based on this theoretical potential, the Swiss government estimated that the country will be able to provide only about 2 MtCO₂ of permanent removals per year, mostly through BECCS.

The SWEET Call 2024 will also partly help estimate the potential of some CDR methods, especially those related to biomass such as BECCS and biochar.

While there is no coordinated national approach, both the Federal Office of the Environment and the Swiss Federal Office of Energy have their own research priorities related to CDR.

The Environment Research Master Plan 2021-2024 ranked CDR as a top research priority. While the Environment Research Master Plan 2025-2028 does not rank CDR as a top research priority anymore, two priority research areas within the “mitigation” dimension are relevant to CDR. These areas are related to social, ethical and governance of new climate technologies, and CO₂ infrastructure.

Moreover, the SWEET Call 2024 released by the Swiss Federal Office of Energy identifies knowledge gaps facing Switzerland by laying out four research challenges:

• Reducing Hard-to-Abate Emissions: Alternative measures, emission reduction, minimising CCS/CDR reliance.
• Swiss CCUTS Infrastructure: Pathways, infrastructure development, carbon capture, transport, storage.
• Sustainable Swiss Biomass: Biomass utilisation, renewable energy, GHG substitution, negative emissions.
• Scaling CCS/CDR: Process development, efficiency improvement, cost reduction, environmental impact, public perception, social acceptance.

The Swiss Federal Office of Energy has also set out its priorities for CDR in the “Research Concept CCUS/ NET for 2023-2028”, focusing on energy-related issues around DACCS, BECCS and biochar.

While there is no dedicated R&D programme for CDR in place at the moment, there have been several funding opportunities providing dedicated funding for CDR within wider research funding calls.

For example, the SWEET 2024 call, which is run by the Swiss Federal Office of Energy, includes a strong CDR component, as detailed above. The SFOE might also develop some other dedicated funding for CDR in the near future, as set out in its “Research Concept for CCUS/ NET 2023-2028”. It also provides pilot and demonstration funding that CDR projects can apply for.

The TA-SWISS foundation, a competence centre directly integrated into the Swiss Academies of Arts and Sciences and financed exclusively through public funding, contains a CDR workstream. This workstream has commissioned a study to explore the opportunities, limits and risks of various CDR methods.

Innosuisse, the Swiss innovation promotion agency, has launched the CDR Booster which provides funding for twelve innovative CDR solutions.

At the national level, several major research projects are underway. For instance, DemoUp Carma, which runs a pilot project on CO₂ transport and exportation abroad, figures prominently in the Swiss CDR and CCS plans. CO2NET explores how to decarbonise the waste incineration sector through CCS and CDR, while DecarbCem assesses CCS and CDR methods to decarbonise the cement industry. The DeCIRRA project compares the role of different CCS and CDR methods in reaching net zero GHG emissions.

Moreover, several national and regional research projects are exploring the potential use of biochar, including a project led by Agroscope and led by the Zürich School of Life Sciences and Applied Management.

After the liquidation of the Climate Cent Foundation in 2012 - the former institution in charge of offsetting the oil motor industry’s environmental footprint - the Swiss government mandated the foundation to use its remaining assets to procure CDR and CCS credits. Consequently, funding agreements for five Swiss projects were signed in August 2023, amounting to around EUR 58 million. The KLiK Foundation, the successor of the Climate Cent Foundation, also lists CDR in its scope for procurement of carbon credits as part of its obligation to offset Swiss motor oil fuel emissions.

Through the CO₂ Ordinance, the Federal government is asked to explore how to support different climate technologies. It is still unclear as to what this will entail and whether CDR would get any additional funding.

The Climate and Innovation Act created a CHF 1.2 billion fund dedicated to the promotion of innovative climate technologies to be spent between 2024 and 2030. As part of the fund, the Government launched a CHF 100 million call for tenders dedicated to CCS and CDR projects. To access this funding, companies must produce a net-zero roadmap, as specified under the Climate and Innovation Act.

Motion 21.4596 on “Aligning the federal administration’s greenhouse gas emissions compensation with the net-zero target” adopted by the National Parliament requires the government to explore how it could compensate all residual emissions from the Swiss administration through the procurement of CDR. If the proposal is implemented, the Swiss administration would become a long-term purchaser of CDR units, helping to shape demand for CDR in Switzerland and abroad.

Through the Swiss agricultural policy, direct payments are provided to farmers for activities that enhance ecosystem services of their lands. For example, maintaining grasslands and planting trees on pastures are eligible activities. There are ongoing discussions about incentivising soil carbon sequestration through this scheme, based on a report on the status of soil carbon sequestration.

Furthermore, the Swiss government proposed to explore how ecosystem services provided by forests could be remunerated by a similar scheme in its latest forestry policy.

The Swiss and EU ETS have been linked since 2020. The current Swiss CO₂ Act does not permit emissions reductions from CCUS to be counted within the Swiss ETS, preventing companies from selling allowances related to these technologies. However, the revised CO₂ Act, expected to take effect in 2025, proposes changes to integrate CCUS into the Swiss ETS, aligning with EU standards. Key revisions include crediting storage in approved underground sites within the European Economic Area, and recognising storage in long-lived products such as building materials, as it is the case in the EU ETS. Biogenic and atmospheric CO₂ will remain outside of the scope of the Swiss ETS.

Additionally, the Swiss CO₂ Act sets an obligation on producers and importers of fossil fuels to offset a share of the emissions they induce through the carbon offset projects and programmes recognised by the CO₂ Ordinance. The minimum share is 5%, and the maximum is 90%, depending on the progress made by the producer/importer towards emission reduction targets, as well as the transport sector’s overall emissions trend. The Federal government has the final say, and must consult the sector first on their plans to reduce emissions. The government can also determine which share of emissions is to be compensated for by projects in Switzerland or abroad. CDR projects are eligible under this scheme.

The Agreement with Managers of Waste Treatment Installations creates a legal obligation for operators of waste treatment installations to put at least one CO₂ capture plant into operation by 2030. The plant(s) should have a minimum capacity of 100,000 tons of CO₂/year. Since a share of the incinerated waste is of biogenic origin, waste incineration with CCS can create negative emissions. The target of 100,000 tonnes of CO₂/year therefore applies both to CCS and CDR.

A revision of the Ordinance on Damage to the Soil (OSol) is planned to anchor the conservation of soil organic matter in legislation. The revised text states that the use of charcoal in soil should not be encouraged until its long-term effects have been assessed. This puts the legal status of biochar into question if biochar is to be applied to soils.

In terms of standards for the built environment, the Swiss Forest Act (article 34b) encourages the Federal government to use sustainably produced timber for the planning, construction and operation of its buildings and installations when appropriate.

Furthermore, the concrete grade calculator, a tool run by the Swiss Coordination Group for Construction and Property Services, includes options for biochar and CO₂ mineralisation, referring to the potential negative emissions induced by these two CDR methods. In parallel, the Swiss CDR Roadmap plans to update the eligibility rules for carbonation in concrete structures, allowing it to count towards climate targets.

Switzerland imposes a CO₂ levy on fossil thermal fuels, such as heating oil and natural gas, which is set at CHF 120 per tonne of CO₂ (equivalent to about EUR 127). The levy is increased if CO₂ emissions from thermal fuels do not decrease at the required pace.

The Swiss legislative process involves a consultative element as part of policymaking. Legislative proposals are drawn up by the Federal government. The draft then goes through a consultation process involving a broad range of stakeholders. These include cantonal governments, political parties, business associations, NGOs, civil society organisations, academics and experts, as well as other interest groups or individuals. This process is key to enabling public participation in CDR decision-making.

The Swiss system is unique in Europe, since Switzerland uses two direct democracy tools, the referendum and the popular initiative. Any new law adopted by the Swiss Parliament is subject to referendum, meaning that if a majority of the Swiss population votes against the law, the law is rejected. Through popular initiatives, any Swiss citizen can propose a revision of the Swiss Constitution (full or partial).

Given the risk of being rejected that any new law faces, public consultations play a key role in Swiss policymaking. Throughout 2024, the government led a public consultation on the Swiss CO₂ Ordinance, which was partly relevant for CDR as the ordinance could unlock new funding for CDR.

About one third of the Swiss CO₂ levy revenues is used to support energy-efficient building renovations and renewable energy heating installation. The rest is redistributed to the Swiss population and Swiss companies.

Additional redistribution mechanisms would have been put in place by the 2021 version of the CO₂ Act, which was turned down by the Swiss population during a referendum. The 2024 version of the CO₂ Act does not include this provision, which means that Switzerland lacks comprehensive mechanisms to achieve a just transition towards net neutrality.

The TA foundation commissioned a study focused on opportunities, limits and risks of various CDR methods, including social, societal and governance aspects as part of its CDR workstream.

DemoUpCARMA also included research into social and ethical dimensions of (BE)CCS, as well as public acceptance as part of its Work Package 5.

Furthermore, ethics, governance, perception and acceptance of new climate mitigation technologies is one of 13 priority research areas of the “mitigation” dimension of the Swiss 2025-2028 Environmental Research Masterplan.

Note: The TA Foundation is a competence centre directly integrated in the Swiss Academies of Arts and Sciences and financed exclusively through public funding.