Directive (EU) 2023/970 required transposition by June 7, 2026. That was four days ago. Swiss parent companies with EU subsidiaries that haven't updated their job ad templates, removed salary-history questions from interview processes, or mapped which reporting thresholds they trigger are already behind in every member state that got its implementing act in order on time. Dr. iur. Servatius von Tatzenberg's piece published today lays out the staggered thresholds — 250, 150, 100 employees — and when the joint pay assessment obligation kicks in. The 5%-gap trigger for a joint assessment is the clause most Swiss groups with German or Dutch subsidiaries will hit first.

The practical enforcement risk is not the regulator. It's the candidate who applies on Monday to a job ad with no salary range and files a complaint on Tuesday. Enforcement in Germany and the Netherlands has historically been complaint-driven and fast.

Casimir von Firn's piece today on the EU Deforestation Regulation (2023/1115) makes the point that most commentary misses: this is not an audit requirement, it's a data requirement. The due-diligence statement your EU importer needs at the customs gate requires plot-level GPS coordinates proving forest-free origin after December 31, 2020. If your supply chain runs through a broker who sourced from a region with poor cadastral records, the geolocation file either doesn't exist or can't be verified — and the goods don't clear.

Large operators have been bound since December 2025. The micro-and-small-enterprise deadline is June 30 — nineteen days out. Swiss exporters of timber, cocoa, coffee, cattle, soy, palm oil, and rubber into the EU are one buyer's failed declaration away from a closed order book. Renegotiating supply contracts to require geolocation data as a condition of payment is no longer a future project.

The Data Act has applied since September 2025, with its switching and egress-fee provisions tightening as contracts renew through 2026. Casimir von Firn's piece today focuses on two clauses: the prohibition on egress fees for switching under Art. 25, and the mandatory 30-day switching assistance period. Hyperscalers have been issuing contract addenda to bring existing agreements into compliance — the risk is that your procurement team signed one of these without flagging it as a material change. Check whether any cloud services agreement was amended in the past six months without legal sign-off.

The IoT obligation is underappreciated. Connected devices deployed in the EU that generate operational data are now subject to user access rights under Art. 3–5, regardless of where the manufacturer is incorporated. If your product team shipped hardware into EU markets, your data terms need to reflect access rights the user holds, not just rights you hold to the data.

Art. 701d OR requires that the articles of association expressly authorise a fully virtual general meeting and that an independent proxy be available. The transitional period under the 2023 Aktienrecht reform has expired. Companies that held virtual AGMs this spring without the conforming charter clause are sitting on a procedural defect. Under Art. 706a OR, shareholders have three months from the AGM date to challenge resolutions.

Casimir von Firn's piece today is the post-season audit counsel needed at this moment. For a company that held its AGM in late March or April, the challenge window closes in late June or July. The resolutions that matter most in a challenge are capital increases, executive compensation approvals, and any M&A-authorisation the board carried through on the strength of the meeting. Check the minutes against the articles now — not together with the 2027 agenda.

The governance chain connection: a contested AGM is also where undisclosed board conflicts from the run-up to the vote become litigation material. If there is any Art. 717a OR conflict-reporting gap alongside the 701d defect, the exposure compounds. See our earlier piece on Art. 717a OR for the protocol requirement.

The consultation on the partially revised AMLO-FINMA (SR 955.033.0) closed two days ago. The implementation timeline is not yet indicated in the FINMA notice. That makes the coming months the natural window to adapt internal ownership-transparency procedures before the text is finalised — the three burden-shifting clauses, which we mapped in our May 16 piece, are worth running through your existing onboarding workflows now, not after the final text arrives.

WBF acted on June 4, with the amendment to Annex 2 of the Sudan sanctions ordinance taking effect June 5 at 23:00. Sudan runs on its own amendment schedule, separate from the Russia/Ukraine cluster, and it has moved twice in the past quarter. If your sanctions screening runs on a weekly batch rather than a daily or real-time feed, verify that the June 5 update landed in the correct cycle — a weekly-batch system typically imports the list on a fixed weekday, and the effective date must fall within your last completed import window.

The April notice flagged ISIL/Al-Qaida list changes (SR 946.231.08, the source for this entry). The Taliban ordinance (SR 946.231.07) is on the same UN-track schedule; confirm recent changes against a separate Taliban-specific FINMA notice. Sudan's WBF cycle moved in early June. Three ordinances, three separate cadences, all active within the past six weeks — if your weekly screening sweep treats anything outside Russia and Belarus as stable, this quarter's activity is the practical counter-argument. The UN 1267 track, as we explained in our May piece, binds from the Security Council resolution date, not from Swiss domestic adoption — the gap is where exposure accumulates.

Both obligations were published in 2023, both had 2025–2026 application dates, and both are being discovered now — one by HR, one by IT procurement. The failure is not legal knowledge; it's organisational routing. The compliance team knew the rules existed. HR and IT didn't know the compliance team knew. Two of today's articles are the same memo reaching two different desks three years late. That is a gap worth naming explicitly in the next cross-functional planning session, not just resolving item by item.

Hunton Andrews Kurth joins Linklaters, Freshfields, and a growing list of international firms that have closed their mainland China offices. For Swiss in-house counsel whose external panel relies on international firms for PRC-law matters: ask explicitly whether your firm still has mainland presence or is routing through Hong Kong, Singapore, or a best-friends arrangement with a local firm. The answer is material for China-nexus M&A and for any transaction where sanctions-screening and PRC regulatory clearance need to be coordinated by people in the same legal system.

Swissinfo revisits the Investitionsprüfgesetz debate. The article frames it as a political curiosity — why is Switzerland building FDI screening at all? The operational question for in-house counsel is simpler and more urgent: at which stage of the deal process does the notification obligation arise? Our May 18 piece puts that answer at the term sheet, not at signing. If you wait until execution to run the screening analysis, you have already locked in a closing timeline that may not accommodate a notification process. The IPG is not light-touch for deals that touch critical infrastructure or sensitive technology — the parliamentary amendments saw to that.

FINMA is relocating its Zürich office from Wasserwerkstrasse 12 to Zürich-Oerlikon. Lower operating costs, more modern premises. If your external auditor or legal team delivers regulatory submissions to the Zürich address: update the template. There is no substantive consequence to this announcement beyond that one line item.