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 does not yet meet all regulatory requirements. FINMA has once again approved the recovery plans for all three institutions.
Systemically important banks must submit an emergency plan and a recovery plan to FINMA annually for assessment. The emergency plan sets out how the continuity of the Swiss systemically important functions can be ensured if they were at risk of insolvency. The recovery plan sets out how the bank can stabilise itself sustainably through its own efforts in the event of a financial crisis.
At this time, FINMA is providing information on its assessment of the plans submitted in 2025. FINMA will report on UBS’s crisis planning separately in late autumn 2026.
Emergency plans for ZKB and Raiffeisen fulfil regulatory requirements
The emergency plans for Zürcher Kantonalbank (ZKB) and Raiffeisen fulfil the regulatory requirements. This assessment does not mean that the continuity of systemically important functions is fully ensured in every conceivable crisis scenario. Compared with global systemically important banks, the regulatory requirements for domestic systemically important banks provide, in particular, for a lower loss absorption capacity. In particularly severe crisis scenarios, this may limit the possible courses of action.
The emergency plan for PostFinance does not yet meet all regulatory requirements. PostFinance has complied with the requirements regarding additional loss-absorbing capital since the end of 2025 and has further developed its alternative strategy. However, the options set out therein in the event that it is not possible to restructure and continue the bank’s operations still need to be further fleshed out. In this context, PostFinance’s statutory mandate to provide a universal service must also be taken into account. The amendment to the Postal Services Act, which is currently undergoing consultation, is intended to reduce legal uncertainty surrounding this.
Recovery plans approved once again
Following the Credit Suisse crisis, FINMA has tightened its requirements regarding recovery planning for systemically important banks. The revised criteria were applied for the first time in the most recent assessment cycle. They include, for example, banks conducting an annual stress test to assess escalation procedures and planned recovery measures, involving the relevant bodies and management. The three domestic systemically important banks have further refined their recovery plans, taking into account relevant lessons learnt from the Credit Suisse crisis. All three institutions have made significant progress in the further development of their recovery plans. FINMA has once again approved the recovery plans for all three domestic institutions.
Some elements of the revised requirements still need to be implemented. This applies, for example, to the documentation of the annual crisis exercises and to updating the crisis communication plans. FINMA expects the identified gaps to be addressed in a timely manner.
