13 · Disclosure — what we have not done

A text that counts must also count what it does not know and has not done. The list below is complete, it is uncomfortable, and it is the reason the rest can be believed. It stands here and not in a footnote, because a text that keeps quiet about its own starting position is worth less — and because each of the preceding twelve counts is worth only as much as the willingness to lay our own beside them.

The sentence that carries all of it, unabridged:

We have never imported a file into a cantonal portal — neither an eCH-0276 file nor an XBRL instance document, in any canton. And we have never sent a call to the swissdec Distributor, not even Ping.

Nothing in this text rests on a test; everything rests on documents. Where a statement about the behaviour of a portal or an interface would have been possible, the wording of the source stands instead. That is not a formula of modesty but the limit of the method: we read, we hashed and we recounted, and we pressed nothing.

What we built for — and which path is open today

The most uncomfortable line in this text is one about us. For Switzerland we built a generator for eCH-0276 V1.0.0 — that is, for the artefact that in the communication matrix of the transmitter specification goes out of a Deklarationslösung, not for the one that goes into it from an accounting system. The research for this text showed two things about that decision.

First: the path a private Deklarationslösung would have to take via the Distributor is the path about which the body carrying the network writes that «zuerst die vertraglichen Grundlagen geschaffen werden» (the contractual foundations would first have to be created). So we built for the track that is contractually suspended. That is our risk, and it stands here because it speaks against us.

Second, and this is the correction to our own earlier version: the open path is not only XBRL out of the accounting system. The rulebook of the SSK, part of the same standard, names for the dialogues Aktiven, Passiven and Erfolgsrechnung three times in identical wording two recognised electronic submission channels: «Wird die E-Bilanz elektronisch übermittelt (Upload oder via Swissdec), können die Positionen nicht überschrieben werden.» (if the E-Bilanz is transmitted electronically — upload or via Swissdec — the positions cannot be overwritten). Upload is a first-class channel inside a component of the standard, and it needs no contract with swissdec. We wrote that too narrowly in an earlier version; the consequence for manufacturers stands in part 14.

What follows from both is not a product announcement but a placement: in Switzerland there is nothing to buy from us, and this text announces nothing. It is the evaluation of research we ran for our own decision.

The inventory list

No Zürich access credentials. Registernummer and Zugangscode arrive by post, per § 4 Abs. 1 LS 631.121, at a Zürich company entered in the Steuerregister. We have none. With that, the precondition for step 4 of our own test sequence is missing, and our spec has said so unchanged for months: «I researched the channel; I have not tested a live Zürich connection — do not claim a working CH transmission until a real import test passes.» (CH-TRANSMISSION.md, test plan).

ebilanzfabrik.ch is not live. The A record still points at the registrar, not at the intended server; what stands there is a parking page without a matching certificate. The CH deploy script has existed since 04.08.2026 and has never been run — no ssh, no DNS change, no request to the domain.

And here we correct ourselves in the act of writing. Our own register (CH-LANDING-OPEN-ITEMS.md, item 10) records that all eight Swiss pages carry <meta name="robots" content="noindex, follow">. Re-measured on 04.08.2026: six of eight carry it — the six legal pages. The two landing pages carry index, follow. In practice that changes nothing, because none of the eight pages is reachable as long as the A record stands. Methodologically it changes everything, and that is exactly why it stands here: we did not take the statement over from our own register, but opened the files.

No Swiss input path. No CH funnel, no upload UI, no template. The existing input path is cut to § 266 HGB; the Swiss side is cut to the OR. No CHF payment path: grep -rin '\bchf\b' across the web app returns zero; the paywall is pinned to a EUR cent amount.

No Swiss legal presence of any kind. No Swiss company, no Swiss address, no UID, no MWST registration, no Steuervertreter under Art. 67 MWSTG, no representative under Art. 14 DSG. No proof of a working hello@ebilanzfabrik.ch mailbox — the only address with a documented receiving path ends in .de.

The provider is a German sole proprietorship; the full provider details stand in the Impressum. No Swiss cross, no flag, no shield, no claim of Swiss origin. In Germany we are in production; in Switzerland nothing is for sale, and this text announces nothing.

The limits of the tooling

Neither Arelle nor lxml is installed on the system — both checked on 04.08.2026 by import attempt. The XBRL statement in this text is therefore a mapping, not a validated instance. On the eCH side, xsd_validate sits permanently in graceful-skip, because the official XSD imports eCH-0007, eCH-0010 and eCH-0129 without schemaLocation and an offline build cannot resolve them. The gate that runs is the structural check of the standard library, not the schema.

What we asked, and what we have no answer to

The query to info@ech.ch — which artefacts a portal actually accepts, and what is advised to a provider that has already implemented against V1.0.0 — sits in our review inbox and has not been sent. The enquiry to info@xbrl-ch.ch about the sample data and the entity identifier scheme is recommended, but not confirmed as sent. Neither open question carries a statement in this text.

The extent of our own reach, which we control and therefore report instead of reporting other parties' states: _PILOT_CANTONS = {"ZH"} and _CH_LEGAL_FORMS = {"GmbH","AG","Verein","Stiftung"}.

Two retractions

The first, shown rather than described. Our note of 04.08.2026 opens with the sentence that the headline of its own predecessor — «kein kantonales Dokument nennt eCH-0276» (no cantonal document names eCH-0276) — is «nun durch zwei Primärquellen falsifiziert» (now falsified by two primary sources). Both notes carry the same date; the file times lie thirty-eight minutes apart. A headline, published and retracted the same afternoon, against the same corpus, by the same author.

The second concerns this text. The statement in our manifest that the two standards do not reference one another at all is wrong — the reference linkbase of the CH-Taxonomie has carried eCH-0276 position codes under the label «Tax code» since 23.06.2024 (part 11). The count in the manifest was right; the conclusion drawn from it was not.

The distinction that decides the matter, verbatim from our own note:

«Unser Standardsatz deckt das Ausführungsrisiko ab (‹wir haben den Import nicht getestet›). Dies hier ist ein Existenzrisiko — ob der Weg für unser Artefakt überhaupt existiert. Das ist nicht dasselbe, und das zweite entscheidet über das Vorhaben.» (our standard sentence covers the execution risk — ‹we have not tested the import›. This one here is an existence risk — whether the path for our artefact exists at all. That is not the same thing, and the second decides the undertaking.)

Errors in our own records

Recalculated before publication, all on 04.08.2026:

• The manifest dates the Zürich media release to 21.07.2025 and even carries that date in the file name. The document itself carries 18.07.2025 in line 55.
• The manifest says «10 SOAP samples», in two places. ls samples/*.xml | wc -l returns 11.
• For Schnittstelle* in ZStB 109c.1 the manifest names 19 in one place and 13 in another. Re-measuring with word boundaries returns 20; the total falls from 32 to 28 as soon as the two renditions of the same Q&A are not counted twice.
• The manifest dates eCH-0276 V1.0.0 to 05.12.2024; the main document says «Beschluss am 2024-12-02» (decision on 2024-12-02) in line 19. 05.12. is the publication date.
• And the figure «64 Artefakte / 338'469 Wörter» (64 artefacts / 338'469 words) from our own briefing note does not reproduce: the tree holds 255 files, 91 MB, of which 57 are text extracts with 331'014 words.

The rule that follows: recalculate every number ourselves before publication, never carry one over from our own manifest. Five deviations in a bundle we wrote ourselves are not an argument against counting. They are the argument for counting twice.

The dating limit we do not cross

The widely circulated figure «produktiver Betrieb ab 2027» (productive operation from 2027) comes from swissdec.ch/ebilanz-info — a page that is neither crawled nor hashed. grep -rn "2027" across the corpus hits in exactly three files, and in none of them does 2027 hang on a swissdec production date. A text whose method is «gezählte Belege mit Prüfsumme» (counted evidence with a checksum) cannot carry its only forward-looking date on an unhashed page. So the documented date stands here: DVS-Vorhaben INM2.084, Leistungsverantwortliche Organisation SSK, Endtermin 31.12.2026, with two measures not marked as completed — M3 «Umsetzung in Pilotkantonen» (implementation in pilot cantons) and M5 «Umsetzung Pilot mit MWST-Verwaltung und Swissdec» (pilot implementation with the MWST administration and Swissdec) — and a budget line that shows zero for 2027. Anyone who wants to use the 2027 figure marks it as «swissdec.ch/ebilanz-info, abgerufen [Datum], ohne Offline-Beleg» (swissdec.ch/ebilanz-info, retrieved [date], without offline evidence).

What is missing from the corpus and therefore carries no statement

Nachtrag 111 of LS 631.121 — that is, the wording before 13.05.2025; the artefact pulled for it, zh/lexfind-631.121.txt, is not text but a corrupted PDF byte stream and carries nothing. Further: the full texts of LS 631.122 and LS 631.43 · ABl 2025-05-23 / OS 80, 149 · §§ 109c, 109d, 133 StG in full text · the swissdec certification test cases [TFBASIS] · [SECPDF]/[SECRXPDF], both behind infopoint.swissdec.ch · the Institutionsliste retrievable on swissdec.ch under § 8.16 · Formular 500 exists only as a PDF and is not extracted, Formular 510 is missing entirely.

All of this stands here without the old rider that it is the only opinion in the text. This text is full of opinion about the situation — about what the documents mean, what happens next and what has to change. That is the point. Opinion about the situation costs nothing but evidence. Opinion about one's own starting position costs something, and that is why it stands here unabridged.

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