Transparency among traders: what has been done and what is missing
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Since the federal reports of 2013 and 2018, described in Part G, the transparency of Geneva’s commodity trading has progressed on several points. Several major traders publish annual and sustainability reports. Some have joined the Extractive Industries Transparency Initiative and publish their payments to governments for their purchases of commodities from state-owned enterprises. Traders subject to the Code of Obligations publish their reports on non-financial matters and their due diligence on conflict minerals.1 The Federal Statistical Office now measures the sector, as Part G showed.
What is missing is well known. The obligation to publish payments to governments does not apply to trading, unless extended by the Federal Council, which has not decided to do so. The ownership structures of the private houses remain opaque to the public. As for the purchase prices paid to the state-owned companies of producing countries, whose importance for Africa Part I demonstrated, they are not published systematically. Finally, voluntary reports are not verified by third parties in a uniform manner. The transparency of Geneva’s commodity trading is thus a partial, chosen transparency, which the non-governmental organisations established in Geneva measure and contest, and whose extension will depend on the debates of 2026–2028 on the counter-proposal and the initiative.
| Obligation | Status in 2026 | Application to trading |
|---|---|---|
| Report on non-financial matters | in force, Art. 964a et seq. CO | yes, for large companies |
| Due diligence on conflict minerals and child labour | in force, Art. 964j et seq. CO | yes, depending on thresholds |
| Transparency of payments to governments | in force for extraction | no, unless extended by the Federal Council |
| Climate reporting | ordinance in force since 2024 | yes, for large companies |
| European duty of vigilance | directive of 2024, simplification under way | yes, for large traders active in the Union |
| Initiative of 2025 and counter-proposal | consultation 2026, vote 2027–2028 | to be determined |
Notes
- Extractive Industries Transparency Initiative, “Le commerce des matières premières” (Commodity trading), eiti.org (accessed September 2026): traders supporting the EITI publish their payments to governments in their reports; Requirement 4.2 of the EITI Standard; first disclosures of prepayments by Trafigura in 2020 according to the EITI guidance note on resource-backed loans, cited in Part I. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.