On 9 September 2026 the Swiss Federal Council adopted an amendment to the Climate Protection Ordinance (KlV) that puts the federal administration under a legally binding net-zero target for 2040 – ten years ahead of the country. The amendment enters into force on 1 November 2026. It implements Article 10 of the Climate and Innovation Act (KlG), the «role model» clause that voters approved in June 2023. For Power-to-X it matters for a simple reason: the Confederation is about to become a buyer of renewable fuels for its own vehicles and aircraft – and the ordinance says nothing about which fuels.
What the ordinance does
The new chapter 5a of the KlV (Articles 30a to 30f) sets the perimeter and the process. The central federal administration must reach or exceed net zero at its Swiss sites by 2040, covering direct and indirect emissions (Scope 1 and 2) and, step by step, the upstream and downstream emissions of its supply chain (Scope 3). The armed forces, the Defence Group, armasuisse and the administration’s sites abroad get until 2050, on the grounds that military systems have long lifetimes and depend on the global armaments market. Cantonal administrations, the decentralised federal administration and federal enterprises such as SBB and Swiss Post are to «strive for» 2040. Remaining emissions must be fully offset with negative emission technologies (NET) from the target year; the Federal Office for the Environment will procure the certificates centrally.
The instrument is the roadmap. Each department, the Federal Chancellery and their «key administrative units» draw up a net-zero roadmap for their area; DETEC consolidates them into an overall roadmap, the DDPS writes a separate one for the military, and the Federal Council adopts both. The first roadmaps cover the 2027–2031 legislature and will be published. Every roadmap must contain an emissions inventory, an analysis of «which solutions can reduce greenhouse gas emissions and to what extent», the measures derived from it, reduction pathways with interim targets, a build-up pathway for NET and adaptation measures. The explanatory report adds that measures are «generally prioritised according to their economic efficiency» and that where the federal budget leaves no room, departments must examine «the abandonment of tasks or other adequate measures, where necessary with changes to the law».
Where the fuel comes in
The ordinance itself is technology-agnostic to the point of silence. Neither the legal text nor the explanatory report mentions electrification, hydrogen, synthetic fuels or Power-to-X. The one place where energy carriers appear is the cost estimate. The additional funding requirement for Scope 1 and 2 – «buildings, mobility and national roads» – is put at around CHF 1.5 billion cumulated over 2027–2040, rising from about CHF 75 million a year in 2027 and 2028 to a good CHF 145 million in 2040. That figure explicitly includes «the switch to renewable energy carriers (e.g. Hydrotreated Vegetable Oil [HVO] as Sustainable Aviation Fuel [SAF])» alongside early infrastructure investments and the cost of NET.
Two things follow. First, the Confederation has concluded that it cannot reach 2040 by replacing its vehicles and aircraft alone; part of the fleet will keep burning liquid fuel, and that fuel must become renewable. The explanatory report is explicit that emissions from vehicles and aircraft used by federal and military personnel are not exempt. Second, the only renewable fuel the administration names today is HVO – a biogenic drop-in fuel whose feedstock is limited and largely imported. Nothing in the ordinance rules out e-fuels; nothing in it plans for them either.
What SPIN asked for, and what happened
In the consultation, SPIN made six requests. The two that mattered most were to anchor technology neutrality in the roadmaps – an analysis that explicitly considers electrification, efficiency, hydrogen, Power-to-X derivatives, synthetic fuels and NET, and a selection of measures that is technology-neutral as well – and to require that technologies be assessed on comparable life-cycle analyses. We also asked that the roadmaps examine renewable molecular energy carriers for applications that are hard, or not quickly enough, to electrify, and that the Confederation’s implementation guides for cantons and federal enterprises cover hydrogen and Power-to-X alongside electrification. The consultation report records the first three requests accurately. None of them made it into the adopted text. Economiesuisse, Swico and scienceindustries argued in the same direction, asking for measures to be prioritised by CO₂ reduction per franc invested, technical suitability and technology openness; that request was answered with the «economic efficiency» sentence in the explanatory report, and nothing more.
The environmental alliance went the other way, proposing a new article under which «investments in installations, equipment and vehicles that emit greenhouse gases in operation are excluded as a matter of principle». That would have ruled out the very fleet the cost estimate plans to run on renewable fuel. It was not adopted either. The Federal Council chose to leave the technology question open – which means it will be decided elsewhere.
Why the next twelve months decide
The ordinance is the frame; the roadmaps are the picture. They are being written now, for adoption by the Federal Council ahead of the 2027–2031 legislature, and the implementation guides that DETEC, the Federal Office of Energy, the Federal Procurement Conference and the KBOB will issue to cantons and federal enterprises are being drafted in parallel. Whatever those documents say about fuel will shape the procurement practice of the federal administration, the armed forces and enterprises such as SBB, Swiss Post and Skyguide for the next decade. By the end of 2028 the Federal Council will also decide how Scope 3 – around 90 per cent of the administration’s footprint, most of it procurement – is to be handled.
Switzerland already has the legal basis for a technology-open answer. Article 11a of the CO₂ Act lets vehicle importers count renewable synthetic fuels towards their fleet targets; the SAF blending mandate is in force at Zurich and Geneva and follows the EU quotas, including the e-fuel sub-target from 2030. A federal administration that fuels its own aircraft with HVO alone while the law it administers requires e-SAF from 2030 would be a strange role model. The consistent course is the one SPIN proposed in the consultation: assess the options on life-cycle terms, prioritise by cost per tonne avoided, and let e-fuels compete for the federal fleet where electrification is not available in time – which, for aircraft and heavy vehicles, is the case.
SPIN will take the question to its political advisory board. The roadmaps are a Federal Council decision, and Parliament has every reason to ask, before they are adopted, whether the Confederation’s own net-zero plan uses the instruments Parliament created.
Sources: Federal Council, press release of 9 September 2026 with the adopted ordinance text and explanatory report; Fedlex, consultation 2025/89 «Anpassung der Klimaschutz-Verordnung» (draft, explanatory report, consultation report); SPIN, consultation response of 19 March 2026.
🤖 AI transparency: This text and its visual were created using AI, reviewed and approved by a human.