Banking stability in Switzerland

UBS's position on regulation

Switzerland is engaged in an important regulation debate about banking stability that will shape the future of the Swiss financial center for years to come. UBS has consistently emphasized the importance of drawing the right lessons from the Credit Suisse crisis and supports the objective of further strengthening the resilience of the financial system.

As a major company, Switzerland’s third-largest private employer and a significant lender to Swiss households and companies, UBS is committed to actively contributing its position to the debate. On this page you find various content on this matter, including media releases, position papers and consultation responses.

UBS remains committed to its globally diversified business model and unique regional footprint. As the largest truly global wealth manager and leading bank in Switzerland, with competitive global investment bank and asset management capabilities, we bring financial stability, expertise, economic benefits and international know-how to our home market Switzerland and our clients globally.

The Swiss financial center is once again at a critical juncture, where the course for the coming decades will be set. UBS will continue to contribute facts and analysis to support an informed discussion and a regulatory outcome that strikes the right balance between financial stability and Switzerland’s ability to remain competitive and grow. We want to ensure that UBS can continue to serve its clients in Switzerland and globally from a position of strength, connecting them to opportunities, expertise and markets around the world. This allows us to further strengthen our resilience and create value for all our stakeholders, including shareholders, clients and employees.
Sergio P. Ermotti

Sergio P. Ermotti

UBS Group CEO

UBS media releases and statements

23 September 2026

UBS statement on decision by Swiss Parliament’s upper house on banking regulation

If confirmed at the conclusion of the ongoing parliamentary process, today’s decision by the Council of States would result in a further excessive tightening of Swiss capital requirements, which are already among the most stringent globally. 

Media releases
Date UBS media releases and statements Link

1 September 2026

UBS statement on WAK-S recommendation on banking regulation

EN

12 August 2026

UBS statement on the consultation launch by the Swiss Federal Council:
“We will analyze the proposals published today by the Federal Council and will contribute to the consultation process. UBS supports a further strengthening of Swiss banking regulation, which is already one of the most stringent globally. Adjustments should be targeted, internationally aligned and proportionate, considering differences in size and complexity of banks operating in Switzerland.”

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22 April 2026

UBS statement on regulatory capital announcements made by the Swiss government

EN

6 June 2025

UBS statement on regulatory proposals made by the Swiss government

EN

Position papers

Too Big To Fail related documents with UBS's position

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Date

Position papers

Languages

21 September 2026

Swiss TBTF discussion – Key Points for the Debate on the Banking Act

EN(PDF, 177 KB) | DE(PDF, 202 KB) | FR(PDF, 194 KB) | IT(PDF, 163 KB)

29 July 2026

Too big to fail - Facts and figures

EN(PDF, 618 KB) | DE(PDF, 644 KB) | FR(PDF, 664 KB) | IT(PDF, 662 KB)

4 February 2026

The Implications of the Capital Regulation Proposals on Switzerland

EN(PDF, 224 KB)

4 February 2026

The UBS Business Model: Risk-Aware, Broadly Diversified and Stable

EN(PDF, 165 KB)

4 February 2026

UBS Position on Share Buybacks

EN(PDF, 149 KB)

4 February 2026

Impact of Rising Capital Requirements on Capital Costs

EN(PDF, 138 KB)

4 February 2026

UBS Position on the Proposed Amendments to the Capital Adequacy Ordinance

EN(PDF, 220 KB)

4 February 2026

The Swiss Regulatory Proposals in the International Context

EN(PDF, 137 KB)

Consultation responses

9 January 2026

Consultation response: capitalization of Foreign Participations

Summary

UBS supports the Federal Council's objective of drawing lessons from the Credit Suisse crisis and strengthening the regulatory framework with targeted, proportionate, and internationally aligned measures. However, the proposed full deduction of foreign subsidiaries from Common Equity Tier 1 (CET1) capital extends far beyond the original proposal from 2024 and clearly does not meet these criteria, which is why we clearly reject the proposal. This measure would put UBS at a significant disadvantage internationally, as UBS would have at least 50% higher capital requirements than its competitors in Europe and the US. These excessive capital requirements would lead to very high costs for the bank and weaken the Swiss financial center and the economy.

Switzerland already has one of the strictest regulatory capital regimes, with substantial progressive capital surcharges, and a conservative and early implementation of the final Basel 3 rules. The Federal Council's proposals would significantly increase the requirements and would contrast sharply with developments in Europe and the US, where de-regulation initiatives have already been announced. This would further worsen Switzerland's international competitive position following the early implementation of Basel 3.

Regulatory adjustments should address the lessons learned from the Credit Suisse crisis in a consistent and targeted manner. The Credit Suisse crisis was primarily the result of the bank's unsustainable strategy and insufficient profitability, inadequate risk management, an inappropriate culture, and weak governance. For too long, Credit Suisse was not forced to take corrective action because regulatory concessions tailored to Credit Suisse undermined the regulations that actually applied. This was also noted by the Parliamentary Investigation Commission (PUK), among others.

In its statement of September 29, 2025, on the amendments to the Capital Adequacy Ordinance, UBS explained that the proposed regulatory valuation of software, deferred tax assets, and regulatory valuation adjustments is a combination of the maximum requirements of various jurisdictions and does not take into account the ultimate impact of the overall package in the respective countries. The proposed requirements were also deemed excessive and not internationally aligned in the statements issued by the business community as a whole, employee associations, banks, cantons with strong financial centers, and business-oriented parties. After consulting with the industry and authorities, the Economic Affairs and Taxation Committees (WAK) of both chambers of parliament spoke out in favor of internationally aligned rules.

The Federal Council's proposal on capital requirements for foreign subsidiaries is based on the extreme assumption that the parent bank must be able to absorb the total loss of all of its foreign subsidiaries during ongoing operations without any negative impact on the parent bank's Common Equity Tier 1 (CET1) capital. The proposal extends far beyond the original objective of the Federal Council's report on banking stability dated April 10, 2024. While the report called for 100% Tier 1 coverage, the new proposal calls for approximately 130% Tier 1 coverage. For UBS, this would result in additional CET1 capital requirements of approximately USD 23 billion and thus very high costs, not only for UBS, but for the entire financial center, households, and companies. The Swiss economy would be weakened.

The proposal to protect Switzerland completely from losses incurred by foreign subsidiaries at all times totally ignores the fact that the TBTF package includes further key measures that significantly increase resilience and were not yet available at the time of the Credit Suisse crisis, e.g., the senior manager regime, expanded restructuring and resolution options, the public liquidity backstop, and the expanded "lender of last resort" function. Furthermore, it does not take into account that Credit Suisse benefited from substantial regulatory relief, so that Credit Suisse's weaknesses were not sufficiently highlighted in official publications, and that UBS operates a balanced and conservative business model compared to Credit Suisse and other G-SIBs.

Foreign subsidiaries are an integral part of the consolidated parent bank's business model. Completely insulating the parent bank from risks arising from foreign business activities that are booked in subsidiaries contradicts the business model of a global bank or any internationally active company, and constitutes a significant restriction on economic freedom. Such a regulation would also only materially affect UBS. Switzerland should not enact laws that are tailored to a single company. The reforms following the financial crisis required certain banking activities that had previously been carried out in branches to be outsourced to subsidiaries in Europe and the US. However, a global bank is dependent on extensive international links in order to provide customer services, including essential support for the Swiss export industry (e.g., loans and financing, foreign currency hedging, payments).

The Federal Council's proposal would represent a single-handed approach, which would isolate Switzerland internationally. Neither the Basel standards nor competing locations have such extreme requirements. Contrary to the description in the explanatory report, the UK and the EU also have significantly less stringent regulations compared to the Swiss proposal.
The explanatory report identified various alternatives to a full CET1 deduction and assessed them as effective. However, the Federal Council has rejected these because they do not meet the extreme objective of zero risk tolerance. The proposal aims to cover extreme crisis scenarios in ongoing business operations. However, systemically important banks develop comprehensive recovery and resolution plans for such scenarios, which are approved by FINMA. In addition, banks must hold substantial incremental Tier 1 in the form of AT1 and convertible debt.

The lessons learned from the Credit Suisse crisis have shown that, on the one hand, existing regulations must be consistently implemented and, on the other hand, subsidiaries must be valued conservatively and without a regulatory filter. This would have made Credit Suisse's parent bank substantially more resilient.

There are significant differences in the cost estimates. The study authored by Prof. Zimmermann in April 2025 shows unrealistically low cost implications. The market estimates the costs to be several times higher than the study. It is our investors and counterparties who determine the cost of capital for UBS and, as a result, for our clients, and these differ considerably from academic findings. The large difference is mainly due to the fact that, in the opinion of the relevant market participants, more equity capital does not lead to lower borrowing costs. We also see that the major rating agencies consider the proposed rules to be potentially positive for creditworthiness, but express concerns about their impact on UBS's cost of capital, competitiveness, and business model. These considerations are consistent with those of financial analysts.

Since the publication of the Federal Council report in April 2024, uncertainty surrounding potentially excessive capital requirements has caused UBS's market valuation to underperform banks in Europe and the US by 27% (approximately CHF 30 billion) through the end of December 2025. For UBS shareholders, this represents a significant destruction of value in addition to the costs of integrating Credit Suisse (approx. USD 14 billion). The partial recovery of the share price in recent weeks due to early December speculation about a possible compromise confirms the relevance of regulation for valuation. However, market participants remain concerned that, although UBS would report very high capital under the proposed regulation, it would not be able to use that capital productively and would therefore lose a great deal of competitiveness.

The material additional costs resulting from the proposal would also place a heavy burden on the Swiss economy, as UBS would have to partially offset the additional costs by increasing prices for loans and services in Switzerland. The Federal Council's argument that UBS would only raise prices abroad fails to take into account that the requirements would be imposed in Switzerland and that UBS would therefore also have to hold the excess capital in its parent bank domiciled in Switzerland. This would happen in an increasingly difficult credit environment with higher refinancing costs. Global economic challenges have also led both the US and the UK to recognize that banking regulation has gone too far and to announce significant capital relief measures in order to provide the economy with additional credit.

The SNB confirms that banks' refinancing costs in the financial market have risen and are having an impact on lending. It mentions that the costs on the Swiss financing market may reflect an adjustment in UBS's risk assessment of loans to former Credit Suisse clients, which is confirmed by UBS analyses. The SNB also points out that stricter regulation is already contributing to higher refinancing costs in the domestic market. Global banks with access to international capital markets, such as UBS, can use their more diversified refinancing sources in such a market environment to help avoid a credit crunch in the Swiss market, even in a difficult economic environment.
The economic impact should be assessed through a thorough regulatory impact assessment before far-reaching decisions are made. According to the authors’ assessment, the BSS study published by the Federal Council does not meet this requirement. The responses to the consultation on the Capital Adequacy Ordinance show that fears of negative effects across the entire economy are widely shared.

Conclusion: UBS rejects the full deduction of foreign subsidiaries from CET1 capital, as this would be disproportionate, not internationally aligned, and not targeted. Furthermore, the lessons learned from the Credit Suisse crisis would not be adequately taken into account. The proposal would lead to significant additional costs and jeopardize the continuation of the successful UBS business model. The existing regime, if applied consistently, would have forced Credit Suisse to make structural adjustments much earlier in order to ensure the company's survival.

29 September 2025

Consultation response: amendment of the Capital Adequacy Ordinance

Summary

UBS supports the Federal Council's objective of learning the lessons from the Credit Suisse crisis and strengthening the regulatory framework with targeted, proportionate and internationally aligned measures. However, the currently proposed capital measures do not meet these criteria. They would put UBS at a significant disadvantage in an international comparison, weaken the Swiss economy and the financial center, and take insufficient account of the lessons learned from the Credit Suisse crisis.

UBS Statement on the Proposed Adjustments to the TBTF Framework

  • Switzerland already has one of the toughest, if not the strictest, regulatory capital regimes in the world.
  • UBS supports the strengthening of financial stability in principle, provided that implementation is targeted, proportionate and internationally aligned.
  • Contrary to the statements of the authorities, there is no overall package. The Federal Council has not sufficiently taken into account the concerns of the experts it has commissioned itself, has not prepared a cost-benefit analysis (including in the submission of 26 September 2025) and has not duly examined alternatives.
  • UBS objects to the extreme capital measures because they are neither proportionate nor internationally aligned and do not adequately take into account the lessons of the Credit Suisse crisis, including the role of the substantial capital relief that had been granted over many years.
  • As a result of the Credit Suisse takeover initiated by the authorities and the proposed adjustments, UBS would have to hold around USD 42 billion of additional capital, which would make the de facto minimum capital requirement around 50% higher than in the EU, UK and USA.
  • The costs of the far-reaching measures would significantly weaken UBS's competitiveness nationally and internationally and would impose considerable additional costs on the Swiss economy in an already difficult environment.
  • There are other, internationally established regulations that would have at least equivalent effect, strengthen resilience in the long term and would not incur disproportionate costs for UBS and the economy.  

Further resources

Study by BAK Economics

The study by the Swiss economic research institute BAK Economics (BAK), which was commissioned by UBS and published on 16 April 2026, contributes to the ongoing discussion regarding the full deduction of foreign subsidiaries from Common Equity Tier 1 (CET1) capital. For the first time, the economic impacts are quantified. UBS defined the scope of the study, while BAK was solely responsible for its scientific execution.

Paper by Yvan Lengwiler, Kumar Rishabh, Rolf Watter: Strengthening the recovery capability of Swiss banks

The paper published in June 2026 highlights the role of Additional Tier 1 instruments (“AT1”) in absorbing losses during the stabilization phase and provides proposals for their further development. The publication was commissioned by UBS; however, UBS had no influence on the conclusions.

How stable is the Swiss banking system – and what role does UBS play?

This video shows the importance of our business model for financial stability, and how we are well prepared to protect the interests of clients and taxpayers alike in all scenarios.