Supervisory activity by sector

As part of its reorganisation, FINMA brought together all groups responsible for on-site inspections in the On-Site Inspections, Quality Control and Auditing section of the new Integrated Risk Expertise division in 2025. This pooling of expertise has enabled FINMA to standardise governance and processes for the annual planning and implementation of on-site inspections. At the same time, it pressed ahead with the operational implementation of the harmonised instruments. Thanks to these measures, FINMA will be able to increase the intensity – in particular the duration and depth – of on-site inspections from the start of 2026 while maintaining the same high quality.

The following on-site inspections took place in the various areas in 2025:

Banking supervision is designed to be risk-based and proportionate. FINMA’s supervisory focus in 2025 was on Credit Suisse’s integration into UBS, and at other banks on the effectiveness of corporate governance, risk culture, compliance with conduct rules, in particular combating money laundering and the banks’ handling of sanctions, the mortgage lending business and cyber risks.

To intensify its supervision, FINMA conducted an increased number of deep dives in 2025, maintaining direct contact with boards of directors, executive boards, compliance and risk management functions and internal audit departments. A focus of these visits were the topics of corporate governance, risk management, risk culture and gaining a deeper understanding of business models.

Measures taken when deficiencies were identified

FINMA identified some serious deficiencies in the course of its ongoing supervision. It called on the banks concerned to remedy the shortcomings without delay. As a direct result of its ongoing supervision, FINMA imposed an institution-specific capital add-on in 14 cases and a restriction on business activity and a ban on takeovers in 7 cases, among other requirements. A total of 16 cases resulted in preliminary investigations. Enforcement proceedings were launched in 15 cases. In 18 cases, FINMA appointed an independent auditor.

To improve the effectiveness of its supervisory activities, FINMA also took action at an earlier stage when deficiencies were identified, imposing supervisory measures more consistently and more systematically, and enforcing these measures. In the case of enforcement proceedings, for example, it increasingly focused on immediate measures and tougher requirements when proceedings were opened, as opposed to exclusively ordering measures when proceedings were concluded.

Supervision of UBS continues to be dominated by the integration of CS

In 2025, the ongoing supervision of UBS was again dominated by the integration of the former Credit Suisse (CS). After the integration work in 2024 had centred on combining the most important legal entities in Switzerland and abroad, the focus in 2025 was on the technical and operational integration of business activities and processes.

FINMA closely monitored the migration of former CS customers to UBS systems and reviewed the technical implementation with the support of an external third party. The migration of customers not booked in Switzerland was completed in 2025. Due to the high number of customers booked in Switzerland, their migration is scheduled to continue into 2026.

Other focal points of supervisory activity were risk-related aspects. These include the appropriate assessment of non-financial risks related to CS customers transferred to UBS, the continuous reduction of risks from CS business that UBS intends to exit, and the full integration of risk management and reporting. Beyond the issues of integration, supervision of the bank’s suitability framework was strengthened in particular to ensure investor protection against the backdrop of the bank’s business model and global orientation, as well as general market trends towards partially illiquid and less transparent investment instruments (e.g. private markets, digital assets). Similarly, the particularly risk-exposed business activities of investment banking – namely corporate and leverage lending as well as prime brokerage – were subject to increased supervisory focus.

FINMA was also responsible for the supervisory assessment of the further standardisation and simplification of UBS’s global legal and operational structures, as well as operational resilience in light of data migration and the subsequent retirement of IT applications that are no longer being used. FINMA will monitor the most important steps in the integration of CS into UBS through to its completion. Here, too, there was a substantial increase in supervision beyond integration-specific aspects. In view of the high potential tail risks associated with new technologies, FINMA placed particular emphasis on assessing the maturity of the bank’s own management of cyber risks and risks associated with third-party providers.

Focus of on-site inspections: banks

In the year under review, on-site inspections at banks focused on the key points of FINMA’s supervisory activity, as described in the 2025 Risk Monitor. In particular, on-site inspections were conducted on the topics of corporate governance, risk management and risk culture in the areas of combating money laundering, mortgage lending and cyber risks. In some cases, FINMA identified serious deficiencies. It called on the banks concerned to remedy the shortcomings without delay. FINMA took a large number of measures as a direct consequence of these on-site inspections (see the “Measures taken when deficiencies were identified” subsection).

FINMA conducted a total of 113 on-site inspections at banks, mostly at institutions in categories 1 to 3. Five more on-site inspections were carried out at banks in supervisory categories 4 and 5 than in previous years, mainly at institutions with increased risks. The on-site inspections resulted in over 500 findings, which FINMA used to derive recommendations for the banks concerned. It closely monitored the implementation of the recommendations and compliance with the deadlines it had set. Where necessary, FINMA conducted follow-up on-site inspections to ensure that the recommendations had been implemented appropriately.

On-site inspections were once again carried out at banks’ outsourcing partners too. Inspections were also performed at subsidiaries and branches of supervised institutions abroad, either by FINMA alone or jointly with foreign supervisory authorities. Conversely, FINMA supported foreign financial market supervisory authorities in their direct on-site inspections in Switzerland.
 

In 2025, the revised Insurance Supervision Act (ISA) and the revised Insurance Supervision Ordinance (ISO) were again a focus of insurance supervision. FINMA stepped up its information and supervisory activities in view of the large number of affected parties. The new legal and regulatory framework strengthens customer protection.

Review of the application of the prudent person principle

The regulatory requirements for the investment activities of insurance companies ensure that such activities are performed in line with the risk capacity, solvency and business activities of the insurance companies.

The requirements relating to investment activities are set out in the ISO and are based on the prudent person principle. Insurance companies must ensure that they invest exclusively in assets whose risks they can adequately assess, monitor, manage and include in their regulatory reporting.

FINMA continued to supervise compliance with these investment requirements in the year under review. To do so, it collected the necessary information and, in some cases, used the results of reviews conducted by third parties it had engaged. FINMA also conducts in-depth reviews of supervised institutions to ensure improved supervision.

Two years of supervision of insurance intermediaries with a focus on customer protection

FINMA assumed a new supervisory role with the introduction of the new regulatory regime for intermediaries on 1 January 2024. The new regulatory regime focuses on customer protection, and FINMA introduced numerous improvements in this area both in 2024 and in 2025. The overwhelming majority of market participants implemented the new requirements and thus contributed to improved transparency, customer information and quality of advice. Intermediaries who were already registered were also required to submit an updated application to FINMA for a follow-up review. Among other things, this covered professional qualifications and the guarantee of irreproachable business conduct.

FINMA focused on the following priorities:

• Prevention: targeted information for intermediaries and their customers about the new obligations
• Quality assurance in insurance distribution: sensitising the insurance industry to its obligations with regard to distribution channels and carrying out on-site inspections of insurance companies’ distribution operations
• Review of tip-offs: triaging and prioritising external reports and, based on them, clarifying facts and taking immediate measures to restore compliance with the law
• Intervention in cases of breaches of the law: in cases of demonstrable breaches of supervisory law, taking measures and, if necessary, filing criminal charges
• Purging the public register: removal from the register of intermediaries who have seriously violated supervisory law

In 2024 and 2025, FINMA received 1,622 external tip-offs and complaints about potential misconduct by insurance intermediaries and insurance companies. In 271 cases, it opened investigations. FINMA also identified around 1,000 market participants who did not have a licence or the necessary qualifications. These unauthorised activities were often linked to incorrect advice, fraud against insurance companies or clients, and cold-calling in health insurance. FINMA is currently conducting various investigations and proceedings in particularly serious cases where a network of market participants engaged in abusive business practices.

Since the new regulatory regime came into force, FINMA has removed from the public register numerous inactive intermediaries and intermediaries who no longer meet the requirements. At the same time, there were 5,203 new entries, with the total number reaching 11,292 by the end of 2025.

Together with the insurance industry, FINMA had to focus increasingly on sub-intermediary structures during the period under review. The violations of supervisory law referred to above often occurred at sub-intermediaries. These acquire customers on behalf of a primary intermediary. FINMA has plans to address this issue inter alia in a new “Insurance intermediaries” circular. In 2025, FINMA also provided the insurance industry with an interface to the public register of intermediaries that enables automated searches.

Safeguarding the interests of insured persons with protective measures in accordance with the ISA

Under the Insurance Supervision Act (ISA), FINMA must take whatever protective measures it deems necessary to safeguard the interests of insured persons if an insurance company fails to comply with the requirements of the law or regulations, or with FINMA’s rulings, or if the interests of insured persons appear to be jeopardised in any other way.

In the year under review, FINMA imposed various such protective measures on an insurance company that had become financially and organisationally unstable. A number of these measures imposed were immediately enforceable, and ultimately no appeals were filed against any of the rulings concerned.

The measures included the requirement of prior approval for the reversal of technical provisions, asset withdrawals (dividends, loans, etc.) and any changes in the executive management of the insurance company. Based on this right to withhold its approval, FINMA prohibited the specific withdrawal of assets in one case and a change at the level of executive management in another.

On-site inspections of insurance companies mainly at large institutions

FINMA performed 43 on-site inspections at insurance companies, most of which were in supervisory categories 2 (including groups) and 3. It verified whether the insurance companies were complying with legal and regulatory requirements. 

FINMA analysed business models, capital adequacy and internal control mechanisms to identify shortcomings at an early stage and intervene in good time. It focused on corporate governance, risk management, the supplementary health and life insurance business, technical provisions, sales management and insurance intermediaries, cyber risks, as well as outsourcings.

On-site inspections encourage sustainable, responsible corporate governance that is equipped to meet the challenges of a changing market. FINMA’s on-site inspections in the year under review contributed significantly to the stability of the Swiss financial centre and to ensuring the long-term protection of insured persons.

Intensified supervision of the sale of life insurance

Customers advised by untied insurance intermediaries cancelled 28.3% of their life insurance policies within the first three years of entering into the contract, often suffering a total loss of the premiums they had paid. Customers advised by tied insurance intermediaries did the same in 17.6% of cases. FINMA stepped up its supervision in this area in recent years. 

Customers can cancel a long-term life insurance policy at any time. However, this incurs high costs if it happens more than 14 days from the date the contract was entered into. A high cancellation rate in the first few years suggests that the insured persons affected were not well advised by the intermediaries.

The direct effects of the reform of the Insurance Supervision Ordinance (ISO), which led to increased customer protection and greater product transparency, are not yet reflected in the cancellation figures.

Steadfast representation of the interests of insured persons with regard to additional benefits in supplementary health insurance

In 2025, FINMA underscored its role as a systematic supervisory authority and a representative of the interests of insured persons. The focus was once again on supplementary benefits in supplementary health insurance. In its press release dated 16 January 2025, FINMA acknowledged the progress that had been made since 2020 in terms of transparency and the pricing of these benefits. This helped keep premiums for supplementary hospital insurance stable or even helped reduce them, despite rising healthcare costs. At the same time, however, FINMA clarified that contracts with doctors and clinics must comply with the supervisory requirements.

Material implementation gaps were particularly evident in the cantons of Geneva and Vaud. These implementation gaps were not only caused by the various supplementary health insurance providers but also, in large part, by the clinics and doctors’ associations concerned. They had delayed negotiations with many insurance companies for years. This led to increased tensions at the end of 2024 and in early 2025: a number of insurance companies refused to reimburse non-compliant invoices, which some media outlets described as “taking patients hostage”. FINMA consistently stood by its position and clearly rejected demands to extend the transitional period for non-compliant contracts.

In spring 2025, various insurers were able to find a solution with several clinics in Geneva and Vaud. Since then, supplementary health insurance benefits have again been covered in the majority of cases.

Overall, claims settlement practices have improved nationwide, although problems remain in some regions. FINMA considers the absence of contractual arrangements with service providers who refuse to comply with supervisory requirements to be a legitimate means of protecting insured persons in the medium and long term and stabilising premiums. 

Licences for SIX x-clear

In 2025, FINMA licensed a new margin model (SREC) and the new SIX x-clear clearing platform, primarily based on an assessment by the SNB. Under the cooperative supervisory approach, and with the assistance of external auditors, the SNB methodically evaluated the new margin model and its implementation in a new uniform clearing platform. At the instigation of FINMA, enhanced portfolio simulations were used to validate the new risk model, considering stress events for all product categories included in the clearing portfolio, as well as temporary parallel operation with the previous model. The latter enabled data problems in particular to be resolved before the go-live.

Until now, SIX x-clear, as the Swiss central counterparty, operated a range of clearing platforms with varying margin models. A margin model describes a mathematical methodology for calculating the collateral requirements that clearing members must deposit to secure their open positions, for example when trading cash equities or fixed-income securities. The consolidation of the clearing systems has enabled SIX x-clear to reduce costs and increase efficiency in cash equities and fixed income clearing. It was also able to reduce IT complexity by reducing the number of systems used and strengthen the resilience of the clearing service as such.

On-site inspections to test the resilience of financial market infrastructures

One focus of the on-site inspections of financial market infrastructures was operational resilience. This also concerned the continuation or restoration of critical functions even in the event of serious but plausible failures within defined tolerances for disruption. In addition, an on-site inspection was carried out to monitor participants admitted to the Swiss Stock Exchange. FINMA also deepened its understanding of incident management in connection with the handling of major IT incidents. Finally, it carried out an on-site inspection on the subject of IT maintenance. Topics relating to IT asset management and the monitoring of end-of-life systems were analysed.

In the area of asset management, FINMA placed an increasing number of institutions under intensive supervision due to various shortcomings. One focus of the reviews was on compliance with rules of conduct in the area of suitability and risk management.

Challenges in the supervision of asset management institutions

The number of institutions that FINMA had to examine with a view to intensive supervision or transfer to intensive supervision rose steadily between 2023 and 2025. This increase relates in particular to asset managers and trustees indirectly supervised by FINMA via supervisory organisations (SOs): 

Of 35 notifications filed by SOs to FINMA in 2025, 21 led to further investigations or intensive supervision by FINMA. In the remaining cases, FINMA considered that the supervisory measures taken by the SOs had not yet been exhausted. In these cases, it referred the reports back to the SOs for further review.

The cases reviewed by FINMA covered a wide range of topics and had varying degrees of complexity. The primary problem areas were adequate organisational structures, proper business conduct, rules of conduct in accordance with the Financial Services Act (FinSA), compliance with capital requirements and combating money laundering.

The cases that the SOs escalated to FINMA in 2025 as well as some cases involving managers of collective assets and other supervised financial intermediaries exhibited certain conduct and risk patterns with regard to investments for clients in private assets. For example, portfolio managers made investments either via foreign fund products without equivalent supervision of foreign unregulated issuers or in structured products. The rapid rise in interest rates following the end of the negative interest rate phase in 2022 led to liquidity problems for many of these investments. FINMA established that the initial and recurring due diligence, as well as risk management, often turned out to be inadequate in the case of these investments. In addition, the financial institutions referred to above did not mitigate conflicts of interest, or did so only inadequately, in particular conflicts of interest between portfolio managers and issuers or managers of the products they invested in, and they did not transparently disclose these conflicts of interest to investors.

In addition, only some of the financial institutions had a process in place for selecting financial instruments based on industry-standard, objective criteria, such as those required when offering both their own and third-party products. In situations like this, investors are exposed to significant risk of loss. Finally, FINMA identified breaches of the obligation under the FinSA to adequately assess the suitability of these illiquid, risky investments for their clients, considering their risk capacity and risk appetite.

On-site inspections in the area of asset management focusing on suitability and risk management

In the year under review, a total of 20 on-site inspections were carried out at institutions in the area of asset management in the relevant supervisory categories 3 to 5. These included 4 fund management companies, 15 managers of collective assets and 1 custodian bank for collective investment schemes. Supervisory categories 3 and 4 accounted for a quarter of the reviews.

By supervising self-regulatory organisations (SROs) and supervisory organisations (SOs), FINMA monitors multi-level supervision in the “parabanking” sector. Under the Anti-Money Laundering Act, SROs supervise professionally active financial intermediaries – such as currency exchanges, money transmitters and other payment service providers, virtual asset service providers, governing bodies of domiciliary companies, leasing and credit providers, and investment companies. In accordance with the Financial Market Supervision Act, SOs supervise portfolio managers and trustees authorised by FINMA.

Shortcomings in the processing of audit reports by supervisory organisations

FINMA conducted three on-site inspections of SOs in 2025. Two SOs saw their audits pushed back to 2026 owing to the ongoing merger process. The key tools for this ongoing supervision are the statutory supervisory audits carried out by external audit firms approved by the SOs. Based on the corresponding audit reports, the SOs may intensify their supervision, conduct more in-depth examinations and, if necessary, take measures to restore compliance with the law. 

In the course of its on-site inspections, FINMA examined whether the SOs are analysing the audit reports promptly and, in particular, how they are responding to the findings and recommendations in them. In some cases, it identified significant shortcomings in the way audit reports are handled. The reports took too long to process, in some cases up to ten months, or were not processed until after the next supervisory audit had been carried out the following year.

At the same time, FINMA found that the SO audit reports containing findings and recommendations were not given priority. This meant that supervisory risks were identified too late in some cases, and the necessary measures were not taken promptly. In some cases, findings were not consistently followed up with the supervised entities, while in others there was a lack of verifiable controls by the SOs on the implementation of the measures at the institution. FINMA required the SOs to establish clear processes and mechanisms to ensure that findings and recommendations in the audit reports are acknowledged and analysed promptly. FINMA expects the SOs to impose the necessary measures on the institutions and systematically monitor their implementation.

Findings from on-site inspections: self-regulatory organisations

In the past few years, FINMA had identified areas for improvement in its anti-money laundering supervision of SROs through on-site inspections. In 2025, it assessed whether and how the SROs had been able to remedy the identified shortcomings. The SROs it examined had dealt comprehensively with the outstanding matters. For example, they completed follow-up work in connection with the risk-based supervision of members and revised their regulations and forms for reporting changes by members.

FINMA also examined how two SROs handled domiciliary companies and complex structures. It analysed the obligations that the SROs place on their members in business relationships with domiciliary companies. FINMA concluded that both SROs address the increased risks associated with domiciliary companies and complex structures. Nevertheless, a number of shortcomings were identified that must be remedied by the SROs.