The Swiss Financial Market Supervisory Authority FINMA has completed its annual assessment of the emergency and recovery plans for the domestic systemically important banks. The emergency plans for Zürcher Kantonalbank and Raiffeisen fulfil the regulatory requirements. The emergency plan for PostFinance is still not ready to implement. The recovery plans for all institutions were approved.
Systemically important banks are required to submit an emergency plan to FINMA for assessment once a year. They must also have a recovery plan approved annually by the supervisory authority. FINMA is now providing information on its assessment of the plans submitted by domestic systemically important banks in 2024.
Assessment of the emergency plans for PostFinance, Raiffeisen and ZKB
The emergency plans for Raiffeisen and Zürcher Kantonalbank (ZKB) fulfil the regulatory requirements. PostFinance does not currently have sufficient and adequate capital to cover losses that are expected at the time the emergency plan is activated (recapitalisation capacity). PostFinance recognised this shortcoming in 2023. It has been building up the corresponding funds since 2024 and will continue to do so until the end of 2025.
PostFinance must also make further progress in improving optionality in the event of a crisis. An alternative strategy must show how the continuity of systemically important functions can be ensured if restructuring is not possible. PostFinance’s alternative strategy does not currently fulfil FINMA’s requirements.
Recovery plans approved
FINMA has approved the recovery plans for the three domestic systemically important banks. Following the Credit Suisse crisis, the assessment focused in particular on the thresholds that are relevant for the triggering of recovery measures by the bank and the scenario analysis. All banks made progress in this area. FINMA has revised its assessment practice for recovery plans in dialogue with the institutions concerned and will apply this from the next assessment cycle.
Plans are assessed annually
Systemically important banks must submit an emergency plan to FINMA for assessment annually in which they show how they would maintain their systemically important functions if they were at risk of insolvency. The systemically important functions are the deposits business and payment transactions (PostFinance, Raiffeisen and ZKB) as well as the short-term lending business (Raiffeisen and ZKB).
Systemically important banks must also submit a recovery plan to FINMA for approval annually in which they show how they could stabilise themselves on a sustainable basis and without government intervention in the event of destabilisation. It is crucial that institutions identify and implement measures at an early stage during a crisis, which requires sound crisis governance and measures that can be defined and implemented in advance.
In contrast to global systemically important banks, domestic systemically important banks are currently not subject to an assessment of their resolvability in accordance with internationally agreed standards (resolvability assessment).
Expanded crisis toolkit for greater resilience
FINMA is in favour of an expanded crisis toolkit that will enable it to restructure institutions in a wide variety of crisis scenarios where there is a risk of insolvency or to remove them from the market, either by selling them or withdrawing them from the market (see information sheet on crisis instruments). FINMA therefore welcomes the adjustments proposed by the Federal Council in the area of recovery and resolution planning and the expansion of the crisis toolkit. In FINMA’s view, both will contribute to strengthening the resilience of the Swiss financial centre.
FINMA will report on UBS’s crisis planning in a separate press release in autumn 2025.
