“Regulatory tightening affects us all”   

Markus, where do we stand in the debate on banking stability almost three years after the events of 2023? 

We’re right in the middle of it. The Federal Council responded to the Credit Suisse crisis with a wide-ranging package of around 30 measures. A consultation on some of these, mainly at the ordinance level, was held last year. Others, mostly at the act level as well as some concerning liquidity, will be the subject of a consultation later this year. This means that they have yet to be debated in the Swiss Parliament.

How does Swiss Banking liaise with the authorities and politicians? 

We foster contact with the SIF, FINMA and the SNB – and of course with politicians. Our dialogue with them is intensive and constructive. As the representative body for the banking sector, we are committed to finding solutions that both further strengthen the financial centre’s systemic stability and safeguard its competitiveness. In our view, this balance has not yet been achieved. Time will tell how successful we are in getting our points across.

What do you see as the most important developments over the past few years? 

Complex and long-term regulatory projects naturally go through multiple milestones. The Parliamentary Investigation Committee’s report in 2024 and the Federal Council’s parameters in 2025 were certainly significant in this respect. We’re particularly critical of the way the federal government has opted to spread the consultations out. At the same time, there still hasn’t been a comprehensive assessment of the macroeconomic impact the measures will have.

What exactly is Swiss Banking doing in these areas?  

Banking stability has been a strategic focus area for us since 2023, so we’ve mobilised considerable resources within our offices and are pursuing close collaboration between departments. We’re also engaging in constructive dialogue with our partner associations, and we value the active involvement of our specialist commissions and steering committees very highly.

Where do you see genuine stability gains, and where do you think they’re lacking? 

The Federal Council’s package tightens the rules across a broad front, from a bank’s capital underpinning and liquidity to corporate governance, various supervisory instruments and recovery/resolution planning. We see genuine opportunities with regard to the senior managers regime, liquidity provision and resolvability in particular. We’re either sceptical about or opposed to other measures where we’re unconvinced about the cost-benefit ratio.

Proportionality is a key term here. Why are differing guidelines needed? 

Proportionality is crucial for our diverse financial centre. It would be wrong to subject all banks – from the systemically important ones to small regional banks – to the same rules. What we urgently need instead are differentiated regulatory requirements that take account of banks’ differing risk situations. This is especially important, for example, with regard to the senior managers regime and the disclosure of information on a bank’s liquidity situation.

How is Swiss regulation positioned relative to that of other countries? 

By global standards, our banks are already subject to strict, solid regulation. It may make sense to adjust the rules here and there, but tightening them across the board would be dangerous. International compatibility is vital, especially against a backdrop of geopolitical and economic tensions around the world, and all the more so with clear tendencies towards deregulation discernible in the EU and the US.

What do you think about updating the liquidity regime? 

We expressly support the optimisation of liquidity provision in a crisis. That is a key lesson to be learnt from the Credit Suisse crisis. Given the speed of potential bank runs in a digital world, rapid access to central bank liquidity is essential. That said, some questions remain concerning the specifics and destigmatisation, i.e. limiting the reputational risks attached to the new Extended Liquidity Facility. It’s important for the SNB to define eligible collateral broadly and for smaller banks not to be forced into it. We’re also expressly in favour of enshrining the public liquidity backstop in national law.

Which regulatory milestones will be most relevant to the industry in 2026? 

In the short term, we’re expecting a decision from the Federal Council on the Capital Adequacy Ordinance and a dispatch on capital backing for foreign participations. We should also see the consultations on the legislative changes concerning corporate governance and liquidity provision starting in the second or third quarter. We’ll be lobbying for effective, practicable, proportionate and internationally aligned solutions. Overall, however, this project remains a moving target that’s heavily influenced by political developments.

How can we communicate these complex issues successfully to society at large, which is indirectly affected by them? 

We actively provide transparency and context, for example through webinars, public appearances and media content. Regulatory tightening affects us all, not just banks. Higher costs due to regulation, for instance, can affect lending policies and thus have a noticeable impact on the real economy. Our nationwide campaign “The River” is intended to encourage fact-based debate on stability and competitiveness and to raise awareness of the role banks play in Switzerland’s success story.