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Corporate climate leadership and its relationship with state regulations are discussed. First, a typology defining corporate climate leadership is introduced and distinguished from the other strategic behaviours corporations may adopt in response to climate change. A conceptual framework to explore the mechanisms enabling corporate climate leadership within a given policy system is then presented. This framework is applied to two big Swiss food retailers, considered as typical of corporate climate leaders, firms that showed an early interest in climate protection, as a result of ecological values, third actors' lobbying and particular market incentives. Most importantly, the two companies were set in motion by a regulatory framework that featured stringent policy goals associated with flexible instruments and economic sanctions. The importance of these findings for understanding the role of corporate leadership in polycentric climate governance is discussed.