Swiss Banking Stability: Navigating Regulatory Changes Three Years After the Credit Suisse Crisis
Three years after the turmoil surrounding Credit Suisse in March 2023, Switzerland is still deeply engaged in reshaping its banking regulations. The Federal Council, Switzerland’s executive body, responded to the crisis with a comprehensive package of approximately 30 measures aimed at bolstering banking stability, reducing risks to the state and taxpayers, and safeguarding the economy. Implementation is ongoing, with consultations and parliamentary debates continuing throughout 2026.
Ongoing Regulatory Review and Consultation
A portion of the Federal Council’s package, particularly at the ordinance level, underwent consultation in 2025. Further consultations, focusing on legal-level changes and liquidity requirements, are scheduled for later in 2026, paving the way for parliamentary deliberation. This phased approach has drawn some criticism for its fragmentation.
Swiss Banking’s Role in the Dialogue
Swiss Banking, the representative body for the banking sector, maintains close contact with the Swiss Financial Market Supervisory Authority (FINMA), the Swiss National Bank (SNB), and political stakeholders. The organization advocates for solutions that balance systemic stability with the financial center’s competitiveness, arguing that the current balance has yet to be achieved.
Key Developments and Concerns
Significant milestones in the regulatory process include the 2024 report from the Parliamentary Investigation Committee and the Federal Council’s benchmarks established in 2025. Swiss Banking has voiced concerns about the fragmented consultation process and the lack of a comprehensive macroeconomic impact assessment of the proposed measures.
Areas of Strengthening and Skepticism
The Federal Council’s package encompasses a broad range of tightening measures, including requirements related to bank capital, liquidity, corporate governance, and supervisory tools. Opportunities for strengthening stability are seen in areas such as liability regimes, liquidity provision, and resolution capacity. However, Swiss Banking expresses skepticism or outright rejection of measures where the cost-benefit relationship is not convincing.
The Importance of Proportionality
Proportionality is a central tenet of the regulatory debate. Given the heterogeneity of the Swiss financial center, a differentiated approach to regulation is deemed essential. Applying the same standards to systemically important institutions and smaller regional banks is considered inappropriate. Regulatory requirements should reflect the varying risk profiles of individual institutions, particularly concerning liability regimes and liquidity reporting.
Switzerland’s Regulatory Position in a Global Context
Swiss banks are already subject to rigorous and robust regulation in a global comparison. While adjustments may be appropriate, a generalized tightening of regulations could be detrimental. In a context of geopolitical and global economic tension, international compatibility is crucial, especially given deregulation trends in the European Union and the United States.
Liquidity Regime and Central Bank Access
Optimizing liquidity provision in crisis situations is a key priority, informed by lessons from the Credit Suisse crisis. Rapid access to central bank liquidity is considered crucial in a digital age where bank runs can occur quickly. Ongoing discussions focus on the configuration and destigmatization of a new “extended liquidity scheme,” including the definition of eligible collateral and avoiding mandatory regimes for smaller banks. The integration of a “Public Liquidity Backstop” into ordinary law is also supported.
Regulatory Milestones for 2026
Key regulatory milestones expected in 2026 include the Federal Council’s decision on the Capital Adequacy Ordinance and its message regarding the treatment of capital from foreign shareholdings. Consultation procedures on legislative changes related to corporate governance and the Liquidity Ordinance are also anticipated. Swiss Banking remains committed to ensuring that solutions are effective, implementable, proportionate, and internationally coordinated.
Transparency and Public Awareness
Swiss Banking emphasizes transparency and contextualization through initiatives like webinars, public statements, and media contributions. The organization highlights that regulatory tightening impacts not only banks but also the broader economy, potentially affecting credit conditions. Their national campaign, “The River”, aims to foster an objective debate on stability and competitiveness and raise awareness of the banking sector’s role in the Swiss economic model.