ISFB Insight
Overview of Regulatory Changes in the First Quarter of 2026
May 27, 2026
The purpose of this post is to provide a brief overview of the key Swiss regulatory announcements made since the February 2026 newsletter that are likely to affect banks and financial institutions.
Changes affecting systemically important banks and measures or proposals currently under discussion at the political level are not addressed.
Top announcements since February 2026
- The investigation conducted by FINMA in 2025 into the risks of digital fraud led to the FINMA Communication 2026/02. It explains that the risks of digital fraud, described as significant from an operational, legal, and reputational standpoint, justify the implementation of concrete measures. The report then lists its findings and expectations.
- On April 21, 2026, FINMA published its 2025 Annual Report. In it, FINMA notes in particular that cyber risks remain a major risk associated with outsourcing. For this reason, on-site inspections were conducted directly at service providers and subcontractors of regulated entities. It should also be noted that, for the first time, specific liquidity stress tests were conducted on Swiss investment funds.
- On April 22, 2026, the Federal Council adopted the draft on amendments to the Banking Act (BA) as well as the Capital Adequacy Ordinance (CAO) and the Bank Liquidity Ordinance (BLO). The draft amendment to the BA submitted to Parliament by the Federal Council was welcomed by both the SNB (link) and FINMA (link) regarding the requirement for systemically important banks to cover the book value of their holdings in foreign subsidiaries with common equity tier 1 capital. This draft has been widely discussed in the press and is still in the political stage. The amendments to the OFR and Oliq will take effect on January1, 2027. These changes strengthen requirements specifically for systemically important banks, but they also modify certain provisions for all institutions.
- On May 12, 2026, FINMA published the draft partial revision of the FINMA Anti-Money Laundering Ordinance (pOBA-FINMA) and its explanatory report. The amendments are intended to implement the recent revision of the Anti-Money Laundering Act (nLBA) and to meet the expectations of the FATF, which has scheduled an evaluation of Switzerland for 2027. It should be noted that the draft pOBA-FINMA now refers to the prevention of coercive measures under the LEmb (Art. 1(1) and Art. 30 draft pOBA-FINMA). The deadline for submitting comments is June 9, 2026.
- On May 20, 2026, FINMA published its new Ordinance on Risk Diversification for Banks and Securities Firms (nORR-FINMA), which will repeal FINMA Circulars 2013/7 and 2019/1, along with its related consultation report. It is scheduled to take effect on January 1, 2027.
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