On 12 August 2026, the Swiss National Bank (SNB) published a press release in which it welcomes the banking regulation measures proposed the same day by the Federal Council. According to the title of the press release, these measures are intended to strengthen “too big to fail” regulations. One point deserves to be made at the outset: these are proposals by the Federal Council, on which the SNB is commenting. The press release speaks of “proposed” and “planned” measures and presents them neither as adopted nor as having entered into force.
The scope of the source should also be clarified. The SNB’s text is short, written in English, and sets out the central bank’s position, not the details of the Federal Council’s plans. The Federal Council’s own documents are not among the sources used for this article.
Weaknesses highlighted by the Credit Suisse crisis
According to the SNB, the planned measures are crucial for addressing the regulatory weaknesses highlighted by the Credit Suisse crisis. The central bank sees them as an important step towards further strengthening the stability of the Swiss financial system.
The press release does not list these weaknesses and does not revisit how the crisis unfolded. Nor does it explicitly link each measure to a specific weakness. One possible reading is that the themes it highlights (liquidity, recovery planning, resolvability, early intervention, cooperation between authorities) correspond to the areas the SNB considers priorities; the source does not, however, put it in those terms.
Liquidity: preparing collateral for the central bank
The aspect the SNB covers in most detail concerns access to liquidity. According to the press release, the draft liquidity ordinance provides that systemically important banks and medium-sized banks must prepare sufficient collateral to be able to access liquidity assistance from central banks.
The SNB explains the rationale behind this requirement: for it to be able to provide liquidity assistance when needed, banks must be able to transfer their assets to it as collateral.
Several pieces of information are missing from the source: the press release does not quantify the volume of collateral required, does not specify which institutions fall into the category of medium-sized banks and does not give an implementation deadline. Moreover, this is a draft ordinance, whose final version is not known at this stage according to the source.
The ELF facility, available from the beginning of 2027
The SNB adds a point that goes beyond the banks covered by the draft ordinance alone. To strengthen financial stability, it says, it is important that as many banks as possible prepare to participate in the Extended Liquidity Facility (ELF), which will be available from the beginning of 2027.
The wording is one of encouragement: the press release does not say that such participation would be mandatory for all banks. Nor does it describe the access conditions or how this facility works.
The other areas supported by the SNB
The SNB states that it also welcomes the other measures proposed by the Federal Council, in particular those concerning:
- recovery planning and resolvability of systemically important banks;
- FINMA’s early intervention powers;
- cooperation between authorities in preventing and managing financial crises.
For these three areas, the press release merely expresses the SNB’s support. It does not describe the content of the measures, nor how they would change the current rules. Readers wishing to know their exact scope will need to refer to the Federal Council’s texts.
A package with the measures announced on 22 April 2026
The SNB places these proposals in a broader sequence. In its view, the measures communicated on 12 August 2026, taken together with those announced by the Federal Council on 22 April 2026, are essential for improving “too big to fail” regulations and strengthening the resilience of the Swiss financial system. The press release does not detail the April measures.
What this would change for the large banks
If the measures were adopted in the form described by the SNB, systemically important banks would be affected on several fronts: preparing collateral to access liquidity assistance from central banks, as well as recovery planning and resolvability. Medium-sized banks would also be affected by the collateral requirement set out in the draft liquidity ordinance.
Beyond these elements, the source does not make it possible to gauge the concrete impact on institutions: it gives no costs, no adoption timetable and no list of the banks concerned. The SNB notes that further information is available on its website.
