Switzerland’s Federal Council has started a consultation on revisions to the Banking Act and the Liquidity Ordinance, advancing a set of post-Credit Suisse reforms for the banking sector.
The Council approved consultation on measures covering governance, supervision, crisis readiness and liquidity arrangements.
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These steps are intended to sit alongside previously adopted capital measures and complete the broader “too-big-to-fail” framework.
Most of the planned changes are directed at systemically important banks.
Some provisions, however, would also extend to other lenders and financial institutions where limiting them to the largest banks would be difficult to justify.
One proposal would introduce a senior managers regime for more complex banks, defined as institutions with at least 250 employees.
Those banks would need to set out clearly which executives are responsible for which decisions.
The government said this is meant to sharpen accountability and clarify the split of duties at top management level.
Some existing governance requirements would also be moved from ordinance into law.
On pay, new broad principles linked to risk reduction and moral hazard would apply across all banks.
For the most senior or highest-paid managers at systemically important banks, variable remuneration would also face retention periods and clawback provisions. FINMA would gain wider authority to step in on remuneration issues.
The plans would also expand FINMA’s supervisory powers.
The regulator would be able to intervene earlier where risks are visible, with the aim of preserving an appropriate organisational structure, preventing further financial deterioration or protecting clients.
FINMA would also be granted the power to fine institutions that fail to comply, impose periodic penalty payments for delays in carrying out orders, and generally disclose completed proceedings to the public.
Recovery and resolution planning for systemically important banks would face stricter and more detailed requirements.
The legal basis for resolution would also be tightened further to improve the practicality of different resolution options.
The package would also widen bank access to Swiss National Bank liquidity.
The draft law would make it easier to transfer collateral to the SNB when seeking liquidity support.
Related changes in the Liquidity Ordinance would deal with preparations for obtaining collateralised liquidity from the SNB or foreign central banks.
Minimum quantitative requirements would apply to systemically important banks.
Mid-sized institutions, referred to as “category 3 banks”, would be allowed to decide how much in assets to prepare using risk indicators in the ordinance.
Smaller institutions in categories 4 and 5 would be outside the scope.
The ordinance changes proposed on 12 August 2026 would take effect once Parliament passes the related amendments to the Act and those changes enter into force.
The consultation will remain open until 19 November 2026.
