Too-big-to-fail regulations: Federal Council adopts dispatch and Capital Adequacy Ordinance

During its meeting on 22 April 2026, the Federal Council adopted the dispatch on the revision of the Banking Act. In the future, systemically important banks in Switzerland will have to fully back their participations in foreign subsidiaries with Common Equity Tier 1 (CET1) capital. This targeted measure is key to strengthening financial stability. Parliament will be able to debate the legislative proposal from summer 2026. At the same time, the Federal Council amended the Capital Adequacy Ordinance. The amendments concern the capital backing for certain balance sheet items such as software, and will come into force on 1 January 2027. The solution proposed by the Federal Council is more moderate than planned, due to the results of the consultation procedure. In terms of capital requirements, the result is thus a balanced overall package that takes account of the comments received.