The Swiss Financial Market Supervisory Authority (FINMA) published on 14 October 2026 its annual assessment of the emergency plans and recovery plans of the three domestically focused systemically important banks. Its finding: the emergency plans of Zürcher Kantonalbank (ZKB) and Raiffeisen meet the regulatory requirements, while PostFinance’s “does not yet meet all the regulatory requirements”. The recovery plans of all three institutions, for their part, have once again been approved.

This announcement should be read for what it is: the supervisory authority’s assessment of documents the banks submitted to it in 2025. It is neither a sanction nor a decision on PostFinance’s future. Its scope is also limited to the three systemically important banks operating mainly in Switzerland: FINMA states that it will report separately on UBS’s crisis planning at the end of autumn 2026.

Two plans, two scenarios

Systemically important banks must submit an emergency plan and a recovery plan to FINMA every year. The two documents do not answer the same question.

The emergency plan, according to the press release, “sets out how the continuation of systemically important functions for Switzerland can be ensured if they are threatened by insolvency”. This is therefore the scenario in which the bank itself can no longer be saved as it stands, but in which some of its activities must keep functioning for the country’s economy.

The recovery plan, for its part, “sets out how the bank can stabilise itself sustainably by its own means in a financial crisis”. It describes the measures the institution would take to recover before things reach that point.

Compliant does not mean infallible

For ZKB and Raiffeisen, the conclusion is positive. FINMA nevertheless takes care to clarify its scope: this assessment “does not mean that the continuation of systemically important functions is fully ensured in all conceivable crisis scenarios”.

The authority points out that, compared with global systemically important banks, the regulatory requirements applicable to domestically focused systemically important banks provide in particular for a lower loss-absorbing capacity. In particularly severe crisis scenarios, this can restrict the options available.

What PostFinance still lacks

The press release acknowledges progress at PostFinance. Since the end of 2025, the institution has met the requirements for additional loss-absorbing funds, and it has continued developing its alternative strategy.

The weak point lies elsewhere. According to FINMA, the options provided for in this strategy for the case where it is not possible to restructure the bank and continue its operations still need to be made concrete. In other words, it is the most extreme scenario, the one in which recovery fails, that remains insufficiently detailed.

FINMA notes an element specific to PostFinance: its statutory universal service mandate must also be taken into account in this context. The authority mentions the amendment to the Postal Act, currently under consultation, which aims to reduce legal uncertainty on this point. This is a legislative project in progress, not an adopted text.

What this means in practice can, at this stage, only be read in the terms of the press release: PostFinance’s emergency plan is “not yet” compliant and must be completed. FINMA does not announce any binding measure. The Keystone-SDA news agency, as reported by swissinfo.ch, notes for its part that PostFinance’s plans have once again failed to convince the regulator.

Recovery: requirements tightened after Credit Suisse

On the recovery side, FINMA says it has tightened its requirements in the wake of the Credit Suisse crisis. The revised criteria were applied for the first time in the latest assessment cycle. They provide, for example, that banks carry out a stress test every year to test their escalation procedures and planned recovery measures, involving the competent bodies and management.

According to the authority, the three banks have refined their plans in light of the lessons from the Credit Suisse crisis and have made significant progress. Some elements of the new requirements still need to be implemented, however, in particular the documentation of the annual crisis exercises and the updating of crisis communication plans. FINMA expects these gaps to be closed within appropriate timeframes.

Sources

  • FINMA: “FINMA assesses the emergency and recovery plans for Zürcher Kantonalbank, Raiffeisen and PostFinance”
  • SWI swissinfo.ch: “Swiss regulator fails PostFinance financial emergency plans”