A move by UBS to the United States or the United Kingdom could cost the bank as much as the "too big to fail" rules planned in Switzerland. That is the conclusion of an internal review by the Federal Department of Finance (FDF), reported by the Reuters news agency and then by Fintechnews Switzerland on 30 October 2026. The review has not been published. UBS, the Swiss big bank, says it does not comment on speculation.

What does the Federal Department of Finance review conclude?

The review seeks to establish whether UBS could escape the tightening of its capital requirements by relocating abroad. According to the FDF, a parliamentary committee requested part of this work. The sources do not say which one.

The department also uses it to defend its plan. In its view, the authorities consider the new rules effective, targeted and proportionate. They regard them as bearable for UBS. This is the position of the federal administration, not that of the bank, which has opposed full coverage of its foreign subsidiaries from the outset.

Why a headquarters in the United States would not lighten the bill

The United States is the option most often mentioned, but the review considers it difficult. American banks generally hold their subsidiaries directly through their parent company. The US caps on the debt and liabilities of that parent company would then apply to UBS. According to the review, the bank would thus have to hold roughly as much capital as it would by fully covering all its subsidiaries.

Relief would remain possible, on one condition. The US authorities would have to accept UBS's current structure, organised around its parent company. The review also warns that US rules could change significantly under a new administration.

And in the United Kingdom?

The United Kingdom treats foreign subsidiaries somewhat more flexibly. But UBS would then have to hold more capital for its activities in Switzerland. British rules would assign them a much heavier risk weighting than today. The review acknowledges that these effects are difficult to measure precisely.

The British framework also differs in its objectives. The British supervisory authority, the Prudential Regulation Authority (PRA), has made the competitiveness of its financial centre a core objective, according to PME magazine. In Switzerland, the director of the Swiss Financial Market Supervisory Authority (FINMA), Stefan Walter, points out that competitiveness is not part of FINMA's mandate.

Switzerland, United States, United Kingdom: the three frameworks compared

The table brings together the conclusions of the FDF review, as reported by Fintechnews Switzerland, and the figures already published on the Swiss debate.

FrameworkRule for foreign subsidiariesEffect on UBS's capital
Switzerland, Federal Council plan100% coverage with hard capital (CET1)Well above the level required today
Switzerland, Council of States version (September 2026)90% coverageAround $16 billion in additional core capital, according to UBS
United StatesSubsidiaries held by the parent company, caps on its debt and liabilitiesRoughly as much as full coverage; relief possible if the current structure is accepted
United KingdomSomewhat more flexible rules for foreign subsidiariesMore capital for Swiss activities; effect difficult to quantify

Too big to fail: where does the debate on UBS's capital stand?

The new rules follow the collapse of Credit Suisse in 2023, taken over by UBS the same year. Under the measures proposed by the Federal Council, UBS would have to fully cover its foreign subsidiaries with hard capital, Common Equity Tier 1 (CET1). In September 2026, the Council of States lowered this target to 90%. Both levels clearly exceed what the bank must hold today.

UBS estimates that the Council of States version would add around $16 billion to its core capital. This figure comes from the bank, not from an authority. At its third-quarter results on 28 October 2026, its chief executive Sergio Ermotti called this vote "very worrying". Coverage of 50% would have seemed more balanced to him, according to finews.ch.

The idea of a departure has been circulating since mid-October. According to the Wall Street Journal, UBS is reportedly studying plans to leave Switzerland: buying an American financial company to move its headquarters there, merging with a European competitor or selling to an American bank. Neither UBS nor Reuters has confirmed this information.

Bank staff then put figures on this scenario. According to finews.ch on 26 October 2026, the Swiss Bank Employees Association (SBPV) estimates that 10,000 to 12,000 of UBS's 34,000 jobs in Switzerland would be at risk. This UBS departure measured in jobs remains an estimate with no published methodology.

What the review changes in the debate

The FDF review responds directly to the departure argument. If its conclusions hold, leaving Switzerland would not spare UBS comparable capital requirements. It is, however, an analysis by the federal administration, known only through the press. It binds neither Parliament nor the bank, and UBS has not commented on it.

What remains to be decided

  • The National Council vote: one of its committees began examining the rules during the week of 26 October 2026, and a vote could take place in December, according to Fintechnews Switzerland.
  • The level of coverage for foreign subsidiaries: 100% in the Federal Council plan, 90% for the Council of States, 50% as wished by Sergio Ermotti.
  • UBS's response: the bank has declined to say what it would do if a strict rule is adopted. It will present its ambitions for 2027 in February 2027.

What we do not know yet

  • The text of the FDF review: it has not been published, and no link to an official document is available.
  • The amounts the review attributes to each scenario, which the sources do not detail.
  • The parliamentary committee that requested part of this work.
  • The timetable for the new rules to enter into force.

Sources