The Swiss Financial Market Supervisory Authority (FINMA) launched a consultation on two new ordinances for banks and securities firms covering risk diversification and liquidity, intended to replace three existing FINMA circulars and move the requirements to ordinance level in line with the regulatory hierarchy set out in Article 7 paragraph 1 of the Financial Market Supervision Act. The proposed FINMA Ordinance on the Risk Diversification of Banks and Securities Firms (RDO-FINMA) and FINMA Ordinance on the Liquidity of Banks and Securities Firms (LiqO-FINMA) would replace FINMA Circulars 2019/1 “Risk diversification – banks”, 2013/7 “Limits on intra-group positions – banks” and 2015/2 “Liquidity risks – banks”. FINMA expects limited new regulatory content from the shift in level, with risk diversification changes focused on measuring trading book positions under the final Basel III standardised approach for market risks (available since 1 January 2025) and updated treatment of guarantees by foreign group entities for intra-group positions. On liquidity, LiqO-FINMA would largely carry over existing Circular 2015/2 content while providing technical implementing provisions for planned amendments to the Federal Council’s liquidity ordinance that are under consultation, including changes linked to “too big to fail” work and an addition to Article 7 paragraph 1 requiring liquidity and financial planning. The consultation runs until 29 September 2025. FINMA plans the new ordinances to enter into force on 1 January 2027, with the three circulars repealed at the same time.

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