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On August 12, 2026, the Swiss National Bank (SNB) welcomed regulatory measures proposed by the Federal Council to strengthen Switzerland's "too big to fail" (TBTF) regulations. The measures address regulatory weaknesses identified during the Credit Suisse crisis and represent a significant step toward enhancing the stability of the Swiss financial system. The proposed measures include amendments to the Liquidity Ordinance, which will require systemically important and medium-sized banks to prepare sufficient collateral for accessing liquidity support from the SNB. Banks must be positioned to transfer assets as collateral to the SNB to enable the provision of liquidity support when needed. The SNB emphasised the importance of banks preparing to participate in the Extended Liquidity Facility (ELF), which becomes available from January 1, 2027. Beyond collateral requirements, the Federal Council's proposals address recovery planning and resolvability frameworks for systemically important banks, expand the Financial Market Supervisory Authority's (FINMA) early intervention options, and strengthen cooperation between authorities in preventing and managing financial crises. The SNB identified these measures as essential components of a comprehensive approach to improving TBTF regulations. Combined with measures announced by the Federal Council on April 22, 2026, these regulatory changes form a coordinated effort to enhance the resilience of Switzerland's financial system and address structural vulnerabilities exposed by recent banking sector instability. Banks should begin preparing for participation in the ELF ahead of its January 2027 launch and ensure compliance with the updated Liquidity Ordinance requirements.

On August 12, 2026, the Swiss Federal Council launched a consultation on amendments to the Banking Act and the Liquidity Ordinance to strengthen the “too big to fail” regulations. The consultation focuses on measures related to corporate governance at banks, supervision and crisis preparedness, including liquidity provisions. The focus is on the senior managers' regime, remuneration, FINMA's tools and powers, recovery and resolution planning for systemically important banks and liquidity support from the Swiss National Bank (SNB). Regarding corporate governance, a senior manager's regime is to be introduced for more complex banks (those with 250 or more employees). Affected banks must define in a document who is responsible for which decisions. This creates a clear division of duties at the senior management level and reinforces managers' personal responsibility. With regard to remuneration, new general principles on risk mitigation and moral hazard will apply to all banks. The rules are designed to promote the long-term positive development of an institution and to counteract unfavourable risk-taking behaviour. The measures would also strengthen the Swiss Financial Market Supervisory Authority's (FINMA) supervisory powers. The proposed amendments would allow FINMA to impose measures earlier and more effectively where risks are apparent, with a view to ensuring that a bank's organisation remains appropriate, preventing a deterioration in the economic situation or protecting the interests of clients. The proposed measures include amendments to the Liquidity Ordinance, which will require systemically important and medium-sized banks to maintain sufficient collateral to access liquidity support from the SNB. Banks must be positioned to transfer collateral to the SNB to enable liquidity support when needed. Interested parties are encouraged to submit their comments by November 19, 2026, via email to vernehmlassung@sif.admin.ch .

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Switzerland's National Bank Welcomes Regulatory Measures to Strengthen Too Big to Fail Framework

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Swiss Federal Council Launches Consultation on Amendments to the Banking Act and Liquidity Ordinance