Published on 22 September 2025
Reduction obligation: Information for installation operators exempt from the CO₂ levy
Installation operators with a reduction obligation undertake to reduce their greenhouse gas emissions and decarbonise their operations. They must submit a report annually regarding their emissions, the measures implemented and any deviations from their targets, as well as updating their decarbonisation plan every three years.
Detailed information on gaining an exemption from the CO2 levy with a reduction obligation can be found in the publication by the FOEN, the enforcement authority.
Key information for installation operators with a reduction obligation:
An operator with a reduction obligation annually submits a report regarding its greenhouse gas emissions, the implemented measures as well as any deviations from the greenhouse gas efficiency target or measures target. This information, as well as the development of the production volumes, serve as control parameters for reaching targets and for any adjustment of the target values as a result of significant changes in operations.
The installation operator also conducts a goods accounting of the quantity of thermal fuels purchased and used. The data is to be depicted in a summary table with the data of the previous year.
The monitoring report must be submitted by 31 May of the following year via the Swiss Federal Office of Energy (SFOE) ZVM tool.
An operator with a reduction obligation can apply to the Federal Office for Customs and Border Security (FOCBS) for a refund of the CO2 levy paid over a period of up to twelve months. The application for a refund must be submitted within six months of the end of the business year in which the operator purchased the fuels on which the levy was paid.
If the application for a refund is not submitted by the deadline, any refund is forfeited. If the reduction obligation has not yet been officially approved, the application for a CO2 levy refund must also be submitted to the FOCBS.
A refund is only given for the levy paid on fossil fuels purchased and used within the system limits of the reduction obligation. For this reason, purchases, sales and the corresponding invoices must be clearly assigned to each installation within the system limits and fully recorded in the goods accounting.
Applications for reimbursement of the CO2 levy can be made via the FOCBS’s Taxas online platform.
An operator with a reduction obligation is excluded from the redistribution of the CO2 levy to the economy. This is done on the basis of OASI invoice numbers. If an operator has the same OASI invoice number for several sites, only the wage bill of employees working at sites exempt from the CO2 levy is excluded from redistribution (partial exclusion).
Operators with a reduction obligation must submit an initial version of the decarbonisation plan to the FOEN by 31 December of the third year of the reduction obligation. The decarbonization plan is flexible in form and must be submitted via the CORE information and documentation system, where a standardised online form containing the relevant key points of the plan must also be completed.
The basis of the decarbonisation plan is the net sum of greenhouse gas emissions from the use of fossil fuels, as well as an analysis and evaluation of proposed decarbonisation measures and an action plan. The decarbonisation plan must set out a reduction path for the greatest possible reduction of direct greenhouse gas emissions from fossil fuels until at least 2040. The reduction path is based on the target of net-zero emissions by 2050.
The decarbonisation plan must be verified by an approved consultant. This service may be carried out by:
- consultants registered by the Federal Office of Energy (SFOE) under the Climate Protection Ordinance;
- advisors of act Cleantech Agentur Schweiz or Energie-Agentur der Wirtschaft (EnAW)
The first version of the decarbonisation plan must be submitted by 31 December of the third year of the reduction obligation, otherwise the obligation will be terminated. The decarbonisation plan must be updated every three years by 31 December.
The FOEN must be informed promptly of any changes of emission-relevant installations and/or legal structures that affect the reduction obligation.
The reduction obligation generally lasts until the end of 2040. However, early termination of a reduction obligation pro rata is possible under the following conditions:
- If the reduction obligation is terminated prematurely as of 31 December 2030.
- If a site has been sold and the new operator does not wish to continue the reduction obligation.
- If a plant operator participates in the ETS for the first time as a result of higher greenhouse gas emissions.
- If an operator at the site no longer uses fossil fuels to generate energy as a rule in normal operation.
- If the conditions for a reduction obligation are no longer met.
Should one of the sites in a pool be released from the pool’s reduction obligation, the reduction obligation continues to apply to the other sites in the pool.
The reduction obligation includes targets for the periods 2025 to 2030 and 2031 to 2040. It is assessed whether the greenhouse gas efficiency target and the measures target are met at the end of the respective period based on the cumulative shortfall in the effect of the measures that would have been required to achieve the annual interim target.
The reduction obligation is deemed fulfilled if the installation operator has met its greenhouse gas efficiency target or measures target in the period (2025–30 or 2031–40) for which it has obtained a CO2 levy exemption.
If an installation operator has not achieved the greenhouse gas efficiency target or the measures target set out in the reduction obligation during the 2025–30 period, it may apply to have national and international emission allowances amounting to a maximum of 2.5% of its actual greenhouse gas emissions in 2025–30 credited towards the fulfilment of the reduction obligation.
Non-fulfilment of the reduction obligation for the greenhouse gas efficiency target and the measures target is assessed at the end of the respective time periods 2025 to 2030 and 2031 to 2040 based on the cumulative shortfall in the effect of the measures that would have been required to achieve the annual interim target value. The crediting of national and international allowances is taken into account.
If, during the obligation period, the FOEN determines on the basis of the monitoring data that an installation operator is no longer on target and there are no corrective measures, a sanction can be applied. This is lifted as soon as the installation operator can prove that it is back on track.
If an operator fails to fulfil its reduction obligation, a sanction of CHF 125 is due for each excess tonne of CO2eq emitted, along with the surrender of a national or international attestation. The excess tonnes of CO2eq emitted are calculated at the end of the respective time period for the greenhouse gas efficiency target and the measures target based on the cumulative shortfall in the effect of the measures that would be required to achieve the annual interim target.