Recovery and resolution

In the year under review, FINMA formally assessed the recovery plan and the emergency plan submitted by the systemically important bank UBS at the end of 2024 for the first time since the merger with CS. While the recovery plan was approved, the emergency plan was found to be largely in line with the applicable legal requirements but did not yet take sufficient account of the risks to the stability of the financial system. FINMA was also able to approve the recovery plans for the domestic systemically important banks. The emergency plans submitted by these institutions at the end of 2024 were assessed by FINMA and, with the exception of PostFinance, fulfil the applicable requirements. Insurance groups had to submit their recovery plans to FINMA for review for the first time in 2025. FINMA will formally assess these, starting from the 2026 submissions. FINMA was once again able to approve the recovery plans for the systemically important financial market infrastructures SIX SIS Ltd and SIX x-clear Ltd in 2025.

As a systemically important bank with an international presence, UBS is required to meet enhanced crisis planning requirements. These include recovery planning, ensuring the resolvability of the entire group, and emergency planning.

FINMA evaluated and formally approved the recovery plan submitted by UBS in 2025 for the first time after suspending this process in the previous two years owing to the ongoing integration of CS. UBS has now fully integrated CS’s former activities in its recovery plan and significantly developed the plan. It has largely implemented FINMA’s new evaluation criteria and incorporated the lessons from the CS crisis.

FINMA prepares a resolution plan to enable it to resolve UBS if it is at risk of insolvency. In addition, FINMA evaluates the bank’s resolvability once a year. UBS made further progress in its resolvability in the year under review, and FINMA continues to view a resolution as feasible.

Furthermore, in line with international practice, FINMA is aiming to expand the options available to resolve UBS. This relates specifically to the two alternative options of a sale of the entire UBS Group and a solvent market exit by means of disposals or the solvent resolution of individual parts of the bank. To ensure the bank can continue its systemically important functions in the event of a solvent market exit, the emergency plan needs to be better integrated in the resolution plan. These aims are in line with the Federal Council’s parameters for the amendment of the Banking Act, which are focused on creating a more flexible but legally secure crisis toolbox.

UBS’s emergency plan submitted at the end of 2024 was largely in line with the statutory requirements. UBS consolidated its emergency plan with CS’s and has begun the work to integrate the emergency plan more effectively in the group-wide resolution plan. However, in its current version, UBS’s emergency plan is as yet unable to ensure the continuity of the banks’ systemically important functions while also paying sufficient regard to the risks to financial stability. FINMA therefore concluded that the emergency plan is currently not ready to be implemented. UBS needs to make further progress in operationalising the resolution options mentioned above and align its emergency plan accordingly. At the same time, the existing legal framework needs to be strengthened in line with the “Focus on expanding the crisis toolkit” section of the Federal Council’s parameters for amendments to the Banking Act.

FINMA evaluated the recovery plans, submitted in 2025, of the three domestic systemically important banks PostFinance, Raiffeisen and Zürcher Kantonalbank against its revised criteria for the first time. These criteria incorporate the lessons from the CS crisis and focus among other things on more rigorous scenario analysis, a more conservative calibration of recovery measures and developing communication strategies. FINMA’s assessment was that all three banks have largely implemented the revised criteria and continued to improve their recovery plans compared with prior years. FINMA approved all three recovery plans on this basis.

The emergency plans need to be improved continuously and must reflect the lessons from the CS crisis. This includes broadening the options for resolution. In addition to continuing as a going concern by means of a restructuring, a solvent market exit also needs to be prepared at the planning level as an alternative strategy. The emergency plans submitted by Zürcher Kantonalbank and Raiffeisen continued to meet the statutory requirements. However, FINMA determined once again that PostFinance’s emergency plan was not ready for implementation. PostFinance did not meet the requirements for additional loss-absorbing funds (recapitalisation capacity) but committed to increase them by the end of 2025. In addition, PostFinance needs to further specify its alternative strategy again.

For the first time since the revised Insurance Supervision Act entered into force, preparing a recovery plan became compulsory in 2025 for the seven Swiss insurance groups and conglomerates Swiss Re Ltd, Zurich Insurance Group Ltd, Swiss Life Holding Ltd, Helvetia Holding Ltd, Baloise Holding Ltd, Swiss Mobiliar Holding Ltd and SIEP Holding Inc. FINMA gave the insurance groups a detailed response on the recovery plans they submitted and will begin evaluating them formally from 2026.

In addition, the insurance companies classified by FINMA as economically important submitted their first recovery plans on a voluntary basis. Preparing a recovery plan will be mandatory for these insurance companies from 2026.

FINMA intensified its dialogue with the Swiss Insurance Association in the year under review. A working group was set up to clarify questions relating to the requirements for recovery plans of insurance groups and economically important insurance companies.

To further strengthen the stability of the Swiss insurance sector, FINMA began preliminary work to draw up resolution plans for the three Swiss insurance groups Swiss Re AG, Zurich Insurance Group AG and Swiss Life Holding AG. In line with this, it notified the Financial Stability Board (FSB) of these insurance groups for its list of insurance companies whose resolution plans are subject to the FSB Key Attributes of Effective Resolution Regimes for Financial Institutions.

FINMA again reviewed the recovery planning of the systemically important financial market infrastructures (FMIs) SIX SIS Ltd and SIX x-clear Ltd in 2025. In accordance with the Financial Market Infrastructure Act (FinMIA) and the Financial Market Infrastructure Ordinance (FinMIO), each of the two FMIs are required to submit three different plans: a recovery plan, a recapitalisation plan and a resolution plan.

FINMA’s evaluation of the recovery planning of SIX SIS Ltd and SIX x-clear Ltd concluded that both institutions’ recovery plans would be approved. Furthermore, FINMA believed the requirements for both institutions’ resolution and recapitalisation plans to have been met. These plans need to show how the FMIs would continue their clearing, settlement and custodial services even in a very severe crisis scenario. To achieve this, they can firstly impose higher collateral requirements and margin calls on their participants in a crisis. Secondly, the FMIs must hold additional capital buffers specially reserved for a crisis.

As the home supervisor, FINMA again organised the meetings of the crisis management groups (CMGs) for the global systemically important bank UBS, the systemically important central counterparty SIX x-clear and the internationally active insurance groups Zurich Insurance Group, Swiss Re, Swiss Life, Baloise and Helvetia in 2025. Furthermore, it maintained an intensive bilateral dialogue with foreign authorities responsible for crisis management and resolution. It held technical consultations with the Bank of England (BoE), the Prudential Regulation Authority (PRA), the Single Resolution Board (SRB) and the European Central Bank’s Single Supervisory Mechanism (ECB SSM).

FINMA also took part in the DACH conference organised by the German Federal Financial Supervisory Authority (BaFin) and the Austrian National Bank (OeNB), at which it discussed specialist issues with the supervisory authorities from Germany, Austria and Liechtenstein. FINMA also welcomed representatives of Asian supervisory authorities during the year under review.

As a member of the Financial Stability Board’s (FSB) Resolution Steering Group (ReSG), FINMA took part in four meetings during the year, where initiatives to improve the crisis preparedness of systemically important banks were discussed. As part of this mandate, FINMA staff also participate in working groups across the FSB. FINMA inputs the experience it gained during the CS crisis in liquidity management and co-ordination between supervisors in banking crises into these discussions.

A special provision on the restructuring of cantonal banks entered into force on 1 January 2023 in Article 28a of the Banking Act. It is intended to ensure that the characteristics of cantonal banks and the role of the cantons as their main owners are given due weight in any resolution process. Under this provision, FINMA must inform the canton concerned without delay if a cantonal bank is at risk of insolvency and consult it when preparing the restructuring plan.

To enable FINMA to fulfil its remit if this situation arises, it needs to carry out the required preparatory work. It can prepare the implementation of the special provisions and determine if there are any impediments to its implementation. To this end, FINMA contacted all non-systemically important cantonal banks in 2025 and obtained the necessary information. In addition to this qualitative analysis of the cantonal banks, FINMA also carried out a quantitative analysis of medium-sized banks to establish the potential for destabilisation at non-systemically important banks.
 

On 4 March 2025, FINMA opened bankruptcy proceedings against SWISS4.0 Ltd. This was a start-up company with a FinTech licence. FINMA opened bankruptcy proceedings as there was a justified concern about over-indebtedness and serious liquidity problems at the institution. The schedule of claims was published in October and lists claims amounting to around CHF 19 million. The claims of the around 250 clients of SWISS4.0 Ltd in liquidation are classified as third-class claims, as they are not privileged or protected by deposit insurance. The main asset in SWISS4.0 Ltd in liquidation’s bankruptcy estate, the software SwissCore, was sold for CHF 1.25 million.

After opening bankruptcy proceedings, FINMA appointed a bankruptcy liquidator in each of the proceedings listed below. The latter is subject to its supervision and reports to it on a regular basis. For information on the progress of the bankruptcy proceedings to date, see the previous annual reports and the reports published on the FINMA website regarding the respective proceedings.

In the bankruptcy proceedings of FlowBank Ltd in liquidation, the bankruptcy liquidator published a first schedule of claims in February 2025. A first preliminary instalment of 60% of admitted third-class claims was paid in April 2025. In December 2025, creditors were notified of a further preliminary instalment of 10% after a second schedule of claims was published in October. Banking operations were discontinued at the end of June 2025 as part of the liquidation. Since then, the transfer of the remaining cash balances and securities has been handled manually.

The bankrupt estate of Banque Privée Espírito Santo SA in liquidation was involved in ten legal cases as at the end of 2025. As the bank is part of a financial group, how claims between the different group companies are treated will be a central part of the bankruptcy liquidation. In spite of the realisation of assets and the inflow of funds, no preliminary instalment could be made in the year under review.

In the proceedings concerning Bank Hottinger & Cie Ltd in liquidation, the creditors received a third preliminary instalment in 2025. In addition, the negotiations with creditors about how to divide up insurance payouts received by the estate were successfully completed. The Higher Court of the Canton of Zurich rejected the appeal of a former client of the bank in a dispute about the schedule of claims. As this ruling was not appealed to the Federal Supreme Court, it has now obtained legal force. Securities pledged as collateral for loans were realised and used to repay a significant proportion of the outstanding loans. After prolonged negotiations, a settlement was reached relating to assets of around CHF 50 million that had been blocked for years by various criminal and civil proceedings. The creditors have approved this settlement. This will make it possible to pay them a fourth instalment.

In the proceedings relating to Lehman Brothers Finance AG in liquidation, the Higher Court of the Canton of Zurich handed down a ruling on the schedule of claims in 2025. This ruling has been appealed to the Federal Supreme Court, and the case is pending. Progress was made in realising illiquid assets. The payout ratio on admitted third-class claims stood unchanged at 67.83%.

The FINMA Insolvency Ordinance (InsO-FINMA) entered into force on 1 October 2025. The ordinance provides further detail on the bankruptcy and restructuring process envisaged in the relevant financial market legislation for the different groups of supervised entities. It replaces the three previous separate insolvency ordinances for insurance companies (FINMA Insurance Bankruptcy Ordinance; IBO-FINMA), banks (FINMA Banking Insolvency Ordinance; BIO-FINMA) and collective investment schemes (FINMA Collective Investment Schemes Bankruptcy Ordinance; CISBO-FINMA), which have been repealed. This project was not controversial and was broadly welcomed in the public consultation on the new ordinance.

FINMA organised the consultations with the Federal Department of Finance (FDF) – comprising the State Secretariat for International Finance (SIF) and the Federal Finance Administration (FFA) – and the Swiss National Bank (SNB) in the Committee on Financial Crises (CFC) within its mandate. The CFC held four scheduled meetings in 2025. The steering committee overseeing the CFC met at the end of the year and took note of the CFC’s work and planning for 2026.