Swiss Financial Market Supervisory Authority finds PostFinance emergency plan still falls short, approves recovery plans for three domestic systemically important banks

The Swiss Financial Market Supervisory Authority has completed its annual assessment of the emergency and recovery plans submitted in 2025 by Zürcher Kantonalbank, Raiffeisen and PostFinance. Zürcher Kantonalbank and Raiffeisen meet the emergency planning requirements, while PostFinance does not yet meet them in full. FINMA approved all three recovery plans after applying tightened criteria introduced following the Credit Suisse crisis. PostFinance has met additional loss absorbing capital requirements since the end of 2025 and further developed its alternative strategy. However, it must provide more detail on options for a scenario in which restructuring and continued operations are not possible, taking account of its statutory universal service mandate. An amendment to the Postal Services Act under consultation is intended to reduce related legal uncertainty. FINMA also cautioned that compliance by Zürcher Kantonalbank and Raiffeisen does not ensure continuity in every conceivable crisis, as domestic systemically important banks are subject to lower loss absorption requirements than global systemically important banks. The revised recovery planning criteria include annual stress tests of escalation procedures and recovery measures involving relevant management and governing bodies. Although all three banks made significant progress, they must still address gaps including documentation of annual crisis exercises and updates to crisis communication plans. FINMA will report separately on UBS’s crisis planning in late autumn 2026.