FINMA’s digital strategy, data-driven supervision and digitalisation in the financial sector

Continuous expansion of data-driven supervision through automation and artificial intelligence

With the targeted expansion of data-driven methods and increased use of artificial intelligence (AI), FINMA is strengthening its ability to identify risks at an early stage, monitor market conduct and improve the protection of investors, creditors and policyholders. Data-driven supervision remains a strategic pillar of FINMA – technology-neutral, risk-based and forward-looking.

FINMA has further expanded its data-driven supervision since the last reporting period and has digitalised and harmonised further processes. New technologies and tools such as AI assistants in particular support efficient work in the supervisory areas. The focus here is placed on time-consuming tasks such as summarising information or documents that are already in the public domain. In addition, the use of AI for defined cases of application is strengthening the effectiveness and efficiency of supervision. FINMA is also making use of new technologies wherever possible and suitable in the area of supervisory technology (SupTech).
 

Data collected for the first time show the significance and diversity of the Swiss asset management sector

In an important step for data-driven supervision, FINMA collected data across sectors for the first time in 2025 concerning the activities of all licensed financial service providers in Switzerland in the areas of portfolio management, investment advice and execution-only services. These categories together make up “assets under supervision”.

The objective was to obtain a uniform and complete market overview of the Swiss asset management sector and be able to identify and address the potential risks better. The data were collected by activity, and some of the assets may have been entered by an institution under different activities. For example, an institution can administer and manage a fund, or a self-managed fund can also be used in customer portfolios.

As at 31 December 2024, the survey yielded assets under supervision totalling CHF 8,772 billion.

The largest share of the recorded assets is managed by banks and securities firms, followed by fund management companies and managers of collective assets. Independent portfolio managers and insurance companies play a significantly smaller role in the overall market.
 

Swiss assets clearly outweigh those of foreign origin.

Asset management largely takes place via individual mandates. Fund assets account for a smaller share. The largest share of the mandates is attributable to execution-only services, while discretionary management and investment advice have less weight.

The largest shares in terms of volume of the total assets under management of CHF 3,848 billion are attributable to managers of collective assets and to banks and securities firms, followed by fund management companies. Mandates for occupational pension schemes also account for a significant share of portfolio management mandates.

These key figures collected according to uniform criteria provide an overview of market distribution and facilitate a differentiated assessment of market participants. They enable FINMA to better assess the risk situation of the asset management activities of all supervised financial intermediaries, because they allow comparisons to be drawn between licence types, institutions and business models and thus support risk-oriented supervision. FINMA can therefore exercise its supervision of asset management activities consistently, proportionately and independently of the type of licence in question and address the associated risks where they are significant.

Direct data survey of capital adequacy improves assessment of risk diversification at banks

Since the implementation of the final Basel III reforms as of 1 January 2025, FINMA has been conducting capital adequacy surveys at banks. Previously, the data survey was conducted by the SNB, which forwarded the data to FINMA. This process is now carried out directly by FINMA via its EHP survey platform. In 2026, FINMA will also conduct the risk diversification survey of banks.

The final Basel III package of measures concludes the international reforms of the Basel Committee on Banking Supervision (BCBS) following the financial crisis in 2008. The new requirements include a comprehensive revision of capital and risk regulations, increased capital adequacy requirements, more uniform valuation approaches and enhanced transparency and comparability. Switzerland has incorporated these standards into national law, with 31 March 2025 as the first reporting deadline under the new framework.

FINMA attaches great importance to the quality of the data submitted. All reports are subject to automated validations and consistency checks supplemented by expert reviews. Irregularities are systematically reviewed and followed up in order to ensure a reliable data basis for supervision.

Data Innovation Lab: innovation for data-driven and efficient supervision

The Data Innovation Lab is FINMA’s innovation vehicle in the area of data-driven supervision. It identifies and tests new technological approaches and translates them into concrete supervisory applications. The focus is on promoting a data-driven, efficient and forward-looking supervisory practice. This strengthens FINMA’s ability to identify risks at supervised institutions at an early stage and understand market behaviour better.

FINMA pooled its analytical competencies from an organisational perspective in 2025 in order to make better use of synergies and provide data-driven internal services more efficiently. Primary responsibility for the Data Innovation Lab was assigned to the newly created Integrated Risk Expertise division. The Lab performs a cross-divisional role and works closely with all FINMA specialist units, gathering ideas from the entire organisation, prioritising them in terms of benefits and impact and developing them further in a structured process. This results in a balanced portfolio of initiatives relevant for supervision.

The focus in 2025 was on strengthening governance and closer interlinking of analytics competencies within FINMA. The Data Innovation Lab worked on a broad range of data-driven supervisory topics. These included projects for automating analyses, utilising text and network analyses, expanding existing AI solutions in specific cases and developing tools for crypto and liquidity supervision. These initiatives show how data-driven innovation can support and further develop supervisory practice in a targeted way.

Additional support is provided by the newly created Analytics Circle as a FINMA-wide platform for the exchange and coordination of analytics initiatives that promotes the internal transfer of knowledge. Among other things, AI-supported processes are used for automated text analysis, where permitted by data classification. They are capable of systematically evaluating large volumes of documents and enable relevant content to be swiftly identified. Media reports, client reviews and social media posts are also increasingly serving as data sources in the analyses in order to gain an even more comprehensive picture of the supervised institutions.

Automating the processing and analysis of account statement data

FINMA automated the standardisation, cleansing and visualisation of account statement data for investigations of unauthorised activities in the year under review. This significantly enhanced the efficiency and quality of the ad-hoc analysis of such data. The basis for automation comprises the edited account documents that are now requested from banks in a structured form and in the format recommended by the Conference of Swiss Public Prosecutors (CSPP) for the electronic edition of bank documents. The data are cleansed at FINMA following receipt, including name matching for the purpose of person-based transaction analyses. In a second step, the cleansed data are made available in an interactive visualisation with selected graphics for investigation tasks. This enables the specialists to concentrate more on content-related investigation questions and work even more efficiently. The standardisation, cleansing and visualisation steps will also be applied in other areas of FINMA in future.

Use of technology in market supervision

FINMA decisively improved its tools for identifying, visualising and evaluating unlawful market conduct in the year under review. In order to effectively assess the many reports of suspicious activity and the data from more than 120 million transaction reports, it relies on intelligent processes and modern technology. This enables potentially price-relevant incidents to be recorded in a systematic and automated manner and subsequently reconciled with incoming reports of suspicious activity.

In addition, the use of AI in cases of suspected insider trading supports the decision as to whether the required price relevance is present and thus facilitates the efficient triage of these cases. If a case is investigated in detail, the unusual, incident-related conduct of a person can be automatically evaluated with the help of historic trading behaviour (so-called “insider scoring”).

Furthermore, FINMA used agile methods to develop new tools for assessing and analysing potential sophisticated market manipulation. The tools enable order book and closing data to be graphically illustrated in a holistic manner on a daily basis or if required up to microsecond level and made suitable for use in court. FINMA presented a prototype of this development upon invitation at the annual Technology Applied to Securities Markets Enforcement Conference (TASMEC) hosted by the International Organization of Securities Commissions (IOSCO) in Rome.

Overall, these technological advances enabled market supervision to further enhance its effectiveness and efficiency.

Challenging supervision of FinTech institutions

Owing to the tense capital and liquidity situation of many FinTech institutions, FINMA at times intensively monitored most of the licensed companies in this supervisory group. The responsible bodies of the institutions were particularly challenged. For example, they had to review different scenarios at an early stage, such as new investors, selling the company or an orderly market exit. FINMA was obliged to withdraw the licence of one FinTech institution despite intensive monitoring and order liquidation by way of bankruptcy. It emerged here that the liquidation values of software developed in-house lay significantly below the valuations that had been estimated on the assumption of a continuation of business activity (so-called going concern principle). The lack of depositor and bankruptcy protection for the client deposits received led to losses for the investors. FinTech institutions are required to comply with the minimum available capital requirements at all times and to pay great attention to their liquidity risks. FINMA expects robust plans to exist at all times, enabling the liquidity requirements to be covered for the next six months.

Authorisation enquiries, preliminary review of projects and licensing procedure

Since 2019, FINMA has received around 30 relevant licence applications from FinTech companies and replied to dozens of preliminary questions in this connection. The applications primarily concerned payment services in fiat money and only in very few cases services involving crypto custody. A relatively large share of the applications did not qualify for a licence. Some of these were insufficiently prepared or did not have a transparent source of funds. Questions also arose in connection with proper business conduct or previous transactions abroad, or complex group set-ups existed that lacked transparency. FINMA granted a total of seven companies a licence by the end of 2025, following the completion of some complex licensing procedures. Four of these companies were still operating at the end of 2025. To enable applications to be dealt with more efficiently, FINMA recommends making use of the newly introduced option of submitting projects to FINMA for a preliminary review. The initial regulatory assessment provides both sides with valuable information at an early stage on any obstacles to licensing or other important issues.

FINMA replied to a large number of enquiries regarding potential duties under financial market regulation, namely 75, about projects in the area of distributed ledger technology (DLT) and crypto in 2025. As in 2024, it responded to such authorisation enquiries in under 30 days on average.

FINMA licenses DLT trading facility for the first time

FINMA licensed Switzerland’s first DLT trading facility in 2025. The DLT legislation had created a new authorisation category for a financial market infrastructure that facilitates the trading of DLT securities. In addition, a DLT trading facility can provide post-trading services such as settlement and/or custody services.

As well as the trading of DLT securities, the licensed DLT trading facility also offers settlement services and is aimed exclusively at supervised participants such as banks and securities firms. Securities settlement takes place by means of a so-called delivery vs. payment smart contract using a public blockchain (Ethereum). The DLT trading facility therefore makes use of the innovative business opportunities introduced with the DLT Act. Payment processing takes place via the Swiss Interbank Clearing (SIC) payment system.

During the licensing procedure, FINMA evaluated some important fundamental issues such as the scope of obligations on the part of issuers, questions concerning the finality of a DLT-based settlement system and also questions concerning effective and technology-specific measures for ensuring business continuity, particularly in the event of disruptions to or failure of the public blockchain. As a small DLT trading facility, the new financial market infrastructure benefits from a certain degree of regulatory relief. At the same time, however, the statutory trading and settlement volume thresholds have to be complied with.

FINMA advocates for adequate consumer protection in crypto regulation

FINMA contributed its expertise to the regulatory project led by the State Secretariat for International Finance (SIF) on an amendment to the Financial Institutions Act (payment instrument institutions and crypto-institutions). It is committed to ensuring that the envisaged amendment of the law offers effective protection for creditors and investors and that the integrity of the Swiss financial centre is not negatively impacted.

The bill proposes two new licence categories: The first is a licence for payment instrument institutions. This licence is intended to replace the existing licence under Article 1b of the Banking Act and allow the issuance of stable cryptobased payment tokens (a specific type of stablecoin). The second is a licence for crypto-institutions, which is intended to enable activities with cryptobased assets such as Bitcoin. Currently, these crypto service providers are only supervised by self-regulatory organisations with regard to the Anti-Money Laundering Act. Apart from this, there are no specific consumer protection obligations such as mandatory risk disclosure. 
As practice shows, consumers take significant risks when purchasing, trading and transferring cryptocurrencies.

FINMA welcomes the progress made on innovation while protecting investors in the consultation draft published on 22 October 2025 and will continue to raise its concerns regarding consumer protection and integrity.

Increased use of artificial intelligence in the Swiss financial market

FINMA continued to monitor and supervise the use of AI at Swiss financial institutions. To this end, it relied on supervisory discussions, data surveys and targeted on-site inspections. FINMA had already published the insights gained from its supervisory activity and its expectations in FINMA Guidance 08/2024.

At the beginning of 2025, FINMA conducted a survey of around 400 supervised institutions on their current and planned use of AI. Banks and securities firms, insurance companies and insurance intermediaries, fund management companies and managers of collective assets and financial market infrastructures were canvassed. The results of the survey show that Swiss financial institutions are increasingly making use of AI. At the time of the survey, around 50% of institutions already had AI applications in use or under development. The use of AI is more widespread among insurance companies than among banks. However, judging by the institutions’ planning, this difference is set to even out in two years’ time.

The widespread use of generative AI (GenAI) is also accompanied by an increasing dependency on external service providers. With this in mind, FINMA once again drew attention to the risks of outsourcing in its 2025 Risk Monitor.

Around half of institutions have defined an explicit AI strategy. Institutions consider the greatest risks posed by the use of AI to lie in data quality, data protection and the insufficient explainability of the results. In addition, risks are identified with regard to model correctness, ethics and bias and for outsourcing.

FINMA is responding to the risks in the field of AI with its approach of “same business, same risks, same rules”. It guarantees transparent and technology-neutral authorisation and supervisory activities so that new and innovative technologies are used on the Swiss financial market in accordance with the regulatory framework. FINMA continues to focus on the topic of AI and is increasingly addressing it in its supervisory activities at the institutions.