Switzerland Consults on Post-Credit Suisse Reforms

The Swiss Federal Council has launched a consultation on amendments to the Banking Act and Liquidity Ordinance that would complete its post-Credit Suisse package of reforms to the country’s too-big-to-fail framework.

The proposals would introduce a senior managers regime for banks with 250 or more employees, requiring firms to document responsibility for key decisions at the senior management level. The Federal Council said the regime is intended to clarify accountability and allow banks or supervisors to respond more directly to misconduct or breaches. “This aims to improve the corporate and risk culture, and promote responsible governance,” the Federal Council explained.

New remuneration principles would also apply across the banking sector. Additionally, the most senior or highly paid managers at systemically important banks would face retention periods for variable compensation and clawbacks.

The reforms would expand the powers of the Swiss Financial Market Supervisory Authority (FINMA). FINMA would be empowered to intervene earlier where risks emerge, impose fines on institutions for non-compliance, levy periodic penalties for delays in implementing supervisory measures, and generally disclose completed proceedings.

Recovery and resolution requirements for systemically important banks would also be strengthened. And banks’ access to liquidity from the Swiss National Bank (SNB) would be expanded by facilitating collateral transfers. Systemically important banks would face quantitative minimum requirements for assets prepared for central bank liquidity, while medium-sized banks would calibrate their preparations based on prescribed risk indicators. Smaller banks would be exempt.

The consultation runs through November 19, 2026.