ISFB Insight

Review of regulatory changes in the last quarter of 2025

February 2, 2026

The purpose of this article is to briefly present the most significant changes coming into effect on January¹, 2026, as well as the main Swiss regulatory announcements impacting banks and financial institutions in the last quarter of 2025.

We will not address changes concerning systemically important banks and measures currently under discussion at the political level.

For your information, the ISFB is organizing a regulatory update seminar divided into six modules from March to May 2026. During the first module, I will provide an overview of recent key regulatory changes.

Content

Key changes effective January¹, 2026
Key texts announced or published during the last quarter of 2025

Key changes effective January 1, 2026

Below is a list of the main changes coming into effect on January¹, 2026:

New FINMA Circular 26/01 on financial risks related to nature: the new circular will come into force on January¹, 2026, for banks in categories 1 and 2. Thanks to transitional provisions, banks in categories 3 to 5 will have to implement it from January¹, 2027.

End of all transitional periods for operational resilience in accordance with FINMA Circular 23/01 "Operational risks and resilience – banks"1: as of January¹, 2026, all requirements will be in force and there will be no further transitional periods. It is important to take into account the guidance provided in FINMA Communication 05/2025 "Operational resilience for banks, persons under Art. 1b BA, securities firms and financial market infrastructures." This communication provides valuable information on market practice and FINMA's expectations (e.g., number of critical functions, types of critical functions, etc.). We discussed the requirements for operational resilience in this post from March 2025.

Automatic Exchange of Information (AEOI): The Automatic Exchange of Information in Tax Matters Ordinance (AEITMO) was updated on January¹, 2026. The Automatic Exchange of Information (AEI) Guidelines were updated on January 16, 2026. The AEI concerning cryptoassets, which was the subject of various discussions in 2025, will come into force no earlier than January¹, 2027.

Maximum interest rate for consumer credit: decrease on January 1, 2026, resulting from the formula set out in the Ordinance on the Federal Act on Consumer Credit (OLCC). A reassessment was necessary due to several consecutive decreases in interest rates. The three-month Saron is used as the reference rate.

Switzerland-United Kingdom Financial Services Agreement: entry into force on January¹, 2026.

Key texts announced or published during the last quarter of 2025

Transparency of Legal Entities Act (LTPM): On October 7, 2025, the Transparency of Legal Entities Act (LTPM) and the revision of the AMLA were published in the Federal Gazette. They will likely come into force on July¹, 2026. On October 15, 2025, a draft of the new Ordinance on the Transparency of Legal Entities and the Identification of Beneficial Owners (OTPM) was published, along with a partial revision ofthe OBA. The consultation period ended on January 30, 2026. It is difficult at this stage to anticipate the extent of the changes that will be made. The authorities' objective is to bring these two ordinances into force on July 1, at the same time as the LTPM and the revision of the AMLA.

Preliminary draft amendment to the Financial Institutions Act (FIA): On October 22, 2025, the Federal Council launched a consultation on the introduction of two new categories of authorization in the FIA in order to improve the regulatory framework for fintech, blockchain, stablecoins, and other cryptocurrencies. The two new categories are (i) payment institutions and (ii) institutions providing services with cryptoassets. Authorization asa payment institution will replace the current "fintech authorization under Art. 1b of the Banking Act." The activity of these institutions will consist of accepting customer assets without remunerating them and without carrying out active transactions with these assets. The draft amendment to the LEFin also provides for rules for the issuance of a certain type of stablecoin (stable payment cryptoassets), which will be reserved for payment institutions. Authorization asa cryptoasset services institution will allow the provision of various services relating to so-called trading cryptoassets. It is expected that these institutions will not provide any services involving financial instruments. This is currently a preliminary draft that has yet to be submitted to parliament. We will have the opportunity to return to this subject.

You can find previous editions of this post on the ISFB website by following this link.