The Swiss Federal Council has launched a consultation on amendments to the Banking Act and Liquidity Ordinance that complete its proposed too-big-to-fail reform package following the Credit Suisse crisis. The measures would strengthen bank governance, FINMA’s supervisory and enforcement powers, recovery and resolution planning for systemically important banks, and access to Swiss National Bank liquidity. While primarily targeting systemically important banks, some requirements would apply more broadly where a narrower scope would be inappropriate. Banks with at least 250 employees would be subject to a senior managers regime requiring documented allocation of decision-making responsibilities. All banks would face new remuneration principles addressing risk and moral hazard, while senior or highly paid managers at systemically important banks would also be subject to retention periods and clawbacks for variable pay. FINMA would gain earlier intervention powers, authority to fine institutions and impose periodic penalties, and a general duty to disclose completed proceedings. Systemically important banks would face tighter recovery and resolution requirements and quantitative minimum standards for assets prepared as collateral for central bank liquidity. Category 3 banks could determine volumes using prescribed risk indicators, while categories 4 and 5 would be exempt. The consultation closes on Nov. 19, 2026. The Liquidity Ordinance amendments would take effect after Parliament passes the related legislative changes and those changes enter into force.

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