A Swiss government internal review indicates that transferring UBS’s main headquarters to another country would impose costs measured in billions of dollars. The document, obtained by Reuters, links the potential expense to upcoming Swiss capital regulations that could require the bank to hold additional hard core equity Tier 1 (CET1) capital of roughly $18 billion.
The analysis notes that relocating to the United States is a primary option under consideration, but it would not be straightforward. In the United States, banks typically operate under a flat‑holding structure, where subsidiaries report directly to the holding company, unlike UBS’s current arrangement in which the group holding company sits above the parent bank, which in turn owns subsidiaries. Swiss officials argue that, because of U.S. restrictions on capital backing for foreign subsidiaries and other rules, the capital needed under a U.S. structure would be comparable to the amount demanded by the proposed Swiss rules. Moreover, U.S. stress‑test requirements are described as stricter than those in Switzerland, while other regulatory aspects may be less restrictive. The review also flags the risk that U.S. regulations could change significantly after a future change of government.
A move to the United Kingdom would expose UBS to somewhat softer rules for foreign subsidiaries, but the Swiss portion of the business would have to be re‑capitalised at a higher risk weight, effectively demanding more equity. The document states that a reliable quantitative assessment of the financial impact of any relocation remains difficult.
A spokesperson for the Swiss Federal Department of Finance (EFD) said the department has examined possible modalities for a UBS seat shift in light of the proposed capital measures. The spokesperson described the Federal Council’s proposal as effective, targeted, proportionate and, importantly, manageable for UBS. UBS declined to comment.
Federal Councilor Karin Keller‑Sutter previously deemed a UBS exodus unlikely, citing legal complexity and higher costs compared with the new capital rules. UBS Chairman said the bank is reviewing its competitiveness with a Swiss headquarters but sees no reason for hasty action. The dispute centers on a proposal that UBS must fully back its foreign subsidiaries with hard CET1 capital. The Council of States recently softened the target from 100 percent to 90 percent, yet both levels remain well above current requirements. A National Council commission began debating the rules this week, requested further government explanations, and plans detailed hearings in November before a possible National Council vote in December.
UBS remains Switzerland’s sole global systemically important bank. Its 2025 annual report shows the holding paid about $1 billion in taxes, and city tax data rank Zurich banks as the largest corporate taxpayers. The Swiss banking union warned that up to 12,000 UBS jobs in Switzerland could be at risk if stricter capital rules force a headquarters relocation.
