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      U.S. GAAP is becoming increasingly relevant for Swiss companies and groups, particularly for organizations with U.S. reporting obligations.

      Clients are facing growing complexity as a result of U.S. listings, investor expectations, cross-border group structures and regulatory requirements, including SEC reporting considerations.

      Swiss companies may also need to manage the interaction between U.S. GAAP, IFRS and Swiss GAAP FER while maintaining high-quality financial reporting.

      At the same time, several market trends are shaping the accounting landscape. Capital-market transparency continues to increase, accounting requirements remain a strong focus, and M&A and carve-out transactions are becoming more complex. As a result, efficient conversion and reporting processes are gaining importance.

      Mohamad Midani
      Mohamad Midani

      Partner, Head of the U.S. Accounting and Reporting Group

      KPMG Switzerland

      Thijs Fransen
      Thijs Fransen

      Partner, Audit, Western Switzerland

      KPMG Switzerland

      What is U.S. GAAP?

      U.S. GAAP, or U.S. Generally Accepted Accounting Principles, is a comprehensive accounting framework used by domestic issuers for financial reporting in U.S. capital markets.

      Issued by the Financial Accounting Standards Board (FASB), it provides detailed guidance on recognition, measurement and disclosure in financial statements. 

      Where is U.S. GAAP required - and how does it apply to Swiss companies?

      U.S. GAAP is generally required for domestic issuers in U.S. capital markets. Foreign private issuers may, in many cases, report under IFRS as issued by the IASB instead.

      For Swiss companies, U.S. GAAP can become relevant in several situations. These include a U.S. listing, reporting by Swiss subsidiaries of U.S. groups, and certain investor or transaction-related reporting requirements in the United States. In Switzerland, companies listed under the SIX International Reporting Standard may prepare their financial statements under either IFRS or U.S. GAAP.

      U.S. GAAP vs IFRS vs Swiss GAAP FER

      When choosing an accounting standard, Swiss companies often compare U.S. GAAP, IFRS and Swiss GAAP FER. The decision depends on reporting objectives, stakeholder expectations, capital‑market access, complexity and cost considerations.  

      All three frameworks are relevant in the Swiss context but differ significantly in scope, level of detail and regulatory environment.

      • U.S. GAAP: rules‑based, highly detailed framework designed for U.S. capital markets and SEC reporting

      • Swiss GAAP FER: modular, principles-based, Swiss true and fair view standard

      • IFRS: globally oriented, more detailed, suitable for internationally active or capital market-oriented companies

      Criterion

      U.S. GAAP

      IFRS

      Swiss GAAP FER

      Primary objective

      Transparent and decision‑useful financial reporting for U.S. capital markets

      Globally comparable financial reporting

      Transparent financial reporting based on a recognized Swiss accounting standard aiming to present a true and fair view

      Regulatory nature

      Financial Accounting Standards Board (FASB)

      International standard issued by the IASB

      Private standard recognized in Switzerland

      Typical users

      U.S.-listed companies, SEC registrants, international groups with U.S. capital‑market exposure, 

      U.S. privately held companies 

      Internationally active and capital

      SMEs, corporate groups, listed companies

      Use in consolidated financial statements

      Yes

      Yes

      Yes

      Use for listed companies in Switzerland

      Yes

      Yes

      Yes

      Key U.S. GAAP topics that often impact Swiss companies

      Swiss companies applying or transitioning to U.S. GAAP often face a number of recurring accounting and reporting topics. These topics often arise in connection with U.S. capital-market activities, cross-border group structures and M&A transactions.

      They may also involve U.S. reporting and internal control requirements. Although some areas are broadly aligned with IFRS, differences in detailed guidance, disclosure requirements and application can still increase complexity in practice.
       

      U.S. GAAP revenue recognition under U.S. GAAP (ASC 606)


      ASC 606 is broadly aligned with IFRS 15. However, differences can arise in application guidance, disclosure requirements and regulator expectations. For Swiss companies, revenue recognition is often a focus area in audits, conversion projects and SEC reviews, particularly for complex contracts and multi-element arrangements.

      Financial instruments and credit losses (e.g. CECL)


      The CECL model generally results in earlier recognition of lifetime expected credit losses than IFRS 9 in many cases and can increase implementation complexity and earnings volatility. This is particularly relevant for banks and for companies with significant receivables or other financial assets.

      Leases under U.S. GAAP
      (ASC 842)


      U.S. GAAP lease accounting differs from IFRS 16 in areas including lease classification, aspects of lease term assessment and reassessment, and expense recognition. In particular, the different lessee models under ASC 842 and IFRS 16 can significantly affect profit patterns, KPIs and covenant calculations, making lease accounting a recurring challenge in U.S. GAAP reporting and conversion projects.

      U.S. GAAP business combinations and purchase price allocation (ASC 805)


      In M&A and carve-out transactions, U.S. GAAP applies detailed rules to purchase price allocation and subsequent accounting. Differences compared to IFRS can affect deal timelines, post-transaction reporting and audit outcomes, particularly for Swiss groups with cross-border structures.

      First-time adoption and conversion projects to U.S. GAAP

      U.S. GAAP adoption and conversion projects are often driven by a U.S. listing, SEC reporting obligations, acquisitions, changes in group structure or group reporting requirements within U.S.-based organizations.

      For Swiss companies, these projects often involve a transition from IFRS, Swiss GAAP FER or Swiss Code of Obligations reporting. They also require companies to apply a more detailed accounting framework with extensive recognition, measurement and disclosure requirements.

      In practice, U.S. GAAP conversion projects go beyond technical accounting differences. They often require changes to accounting policies, reporting processes, systems and controls, as well as careful planning around comparative information and disclosure requirements.

      Early planning and a structured approach are critical to manage complexity, align stakeholders and avoid delays, particularly in capital-markets transactions or audit-readiness projects.

      How KPMG Switzerland brings U.S. GAAP and Swiss context together

      Applying U.S. GAAP in a Swiss environment requires more than technical accounting expertise.

      It involves understanding how U.S. accounting, reporting and internal control requirements interact with Swiss regulatory frameworks, group structures and market practices.

      KPMG Switzerland combines deep U.S. GAAP knowledge with a strong understanding of the Swiss accounting, regulatory and capital‑market landscape.

      Swiss companies benefit from integrated teams that connect local expertise with international U.S. GAAP and SEC know‑how. This approach helps bridge differences between U.S. and Swiss reporting expectations. It also supports consistent application across group structures and enables efficient coordination with U.S. stakeholders, auditors and regulators.

      As a result, Swiss companies can address U.S. GAAP requirements in a way that reflects local realities and meets international reporting and governance expectations.

      How can KPMG help?

      We support companies that require application of US accounting and auditing standards. 

      Discover our services

      FAQ on U.S. GAAP for Swiss companies

      U.S. GAAP is the U.S. accounting framework for financial reporting, with the FASB Accounting Standards Codification as its main authoritative source.

      It is generally required for U.S. domestic SEC registrants, while foreign private issuers may use U.S. GAAP or, in many cases, IFRS as issued by the IASB in SEC filings.

      U.S. GAAP is relevant for Swiss companies with U.S. listings, U.S. subsidiaries, U.S. investor reporting requirements or cross‑border group structures involving the U.S. capital markets.

      Yes. SIX Swiss Exchange recognizes U.S. GAAP for issuers under several reporting standards, including the International Reporting Standard.

      U.S. GAAP is a detailed, rules‑based framework designed for U.S. capital markets, IFRS is a globally oriented principles‑based standard, Swiss GAAP FER is a proportionate Swiss true‑and‑fair‑view framework, and the Swiss Code of Obligations focuses on statutory minimum requirements.

      A Swiss group may consider converting to U.S. GAAP in connection with a U.S. listing, increasing U.S. investor requirements, a change in group structure, or significant U.S.-related capital‑market transactions.

      Foreign private issuers using U.S. GAAP in SEC filings must comply with SEC reporting requirements, including Form 20-F and Regulation S-X.

      Where an audit report is included in an SEC filing, PCAOB standards are relevant for the auditor, and internal-control reporting requirements may also apply depending on the issuer’s status.

      Swiss subsidiaries of U.S. groups typically prepare reporting packages under U.S. GAAP that align with group accounting policies, disclosure requirements and internal control frameworks.

      U.S. GAAP conversion or IPO readiness projects typically span multiple phases, including diagnostic, policy alignment, implementation and reporting, with timelines depending on complexity, availability of comparative information and capital‑market requirements.

      U.S. GAAP figures can be an important starting point for Swiss tax and regulatory analyses, including Pillar Two assessments, but additional adjustments and reconciliations are often required.

      Swiss groups should therefore align accounting, tax, and regulatory reporting processes carefully.

      Meet our experts

      Mohamad Midani
      Mohamad Midani

      Partner, Head of the U.S. Accounting and Reporting Group

      KPMG Switzerland

      Thijs Fransen
      Thijs Fransen

      Partner, Audit, Western Switzerland

      KPMG Switzerland

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