The Swiss Financial Market Supervisory Authority FINMA has completed its annual assessment of the emergency and recovery plans for domestic systemically important banks. The emergency plans submitted by Zürcher Kantonalbank and Raiffeisen fulfill the regulatory requirements. Conversely, the emergency plan for PostFinance does not yet meet all regulatory requirements. Meanwhile, FINMA has once again approved the recovery plans for all three examined institutions.
Systemically important banks must submit both an emergency plan and a recovery plan to FINMA on an annual basis for evaluation. The emergency plan outlines how the continuity of Swiss systemically important functions can be ensured if the institutions face the risk of insolvency. The recovery plan details how a bank can sustainably stabilize itself through its own efforts during a financial crisis. FINMA is currently providing information regarding the assessment of the plans submitted in 2025, and intends to report separately on the crisis planning of UBS in late autumn 2026.
The regulatory approval for the emergency plans of Zürcher Kantonalbank and Raiffeisen does not indicate that the continuity of systemically important functions is fully assured in every conceivable crisis scenario. Compared with global systemically important banks, the regulatory requirements set for domestic systemically important banks provide for a lower loss absorption capacity in particular. In especially severe crisis scenarios, this factor may limit the available courses of action.
PostFinance’s emergency plan does not yet satisfy all regulatory mandates. PostFinance has complied with the requirements concerning additional loss-absorbing capital since the end of 2025 and has also further developed its alternative strategy. Nevertheless, the options outlined within that strategy for situations where it proves impossible to restructure and continue the bank’s operations still require further elaboration. This process must account for PostFinance’s statutory mandate to provide a universal service. The amendment to the Postal Services Act, currently undergoing consultation, aims to reduce the legal uncertainty surrounding this issue.
Following the Credit Suisse crisis, FINMA tightened its requirements for recovery planning among systemically important banks, applying the revised criteria for the first time in the latest assessment cycle. These measures include banks conducting an annual stress test to evaluate escalation procedures and planned recovery measures while involving the relevant bodies and management. The three domestic systemically important banks have further refined their recovery plans by incorporating relevant lessons learned from the Credit Suisse crisis, with all three institutions achieving significant progress in this development.
Certain elements of these revised requirements still require implementation, including the documentation of annual crisis exercises and the updating of crisis communication plans. FINMA expects the identified gaps to be addressed in a timely manner.
