Swiss Federal Council proposes bonus clawbacks and tighter bank oversight after Credit Suisse collapse

Tighter accountability for bank executives

The Swiss Federal Council on Wednesday opened public consultation on a package of 12 measures to tighten banking oversight, targeting bonus structures and management accountability at systemically important banks. Finance Minister Karin Keller-Sutter presented the proposals at a media conference in Bern. The measures aim to close gaps in Switzerland's "too big to fail" regulatory framework, exposed by the collapse of Credit Suisse in 2023 and the 2008 financial crisis. The Federal Council had already announced the measures in June 2025.

Under the proposed changes, banks with more than 250 employees must establish an accountability regime clearly designating which senior officials are responsible for specific decisions. The 250-employee threshold follows the SECO definition of a medium-sized enterprise. The provision directly addresses the Greensill scandal, which contributed significantly to Credit Suisse's downfall: the bank had claimed it could not identify who internally was responsible for the matter. Systemically important banks affected include UBS, Postfinance, Raiffeisen, and certain cantonal banks.

Bonus clawbacks and deferred payouts

The Federal Council proposes a multi-year waiting period before part of the variable compensation owed to top managers and highly paid employees at all banks can be paid out. In cases of misconduct or rule violations, these compensation components must be reduced, cancelled, or clawed back.

This compensation component must be linked to the future performance and risk development.

The backdrop is stark: Credit Suisse recorded 3 billion Swiss francs in losses over the last ten years of its existence while paying out 32 billion in bonuses. Former managers such as Ulrich Körner, Axel Lehmann, Tidjane Thiam, and Urs Rohner retained their bonuses despite the bank's failure. The Federal Council had halted further bonus payments to Credit Suisse top management during the collapse, but the Federal Administrative Court ruled otherwise, and the case is now pending before the Federal Court.

Expanded powers for FINMA

The financial market supervisor FINMA, heavily criticized for its handling of the Credit Suisse collapse for acting too late and with insufficient authority, would gain significant new powers. It could impose fines of up to 10 percent of a bank's annual operating result, issue professional bans against individual bankers, and actively inform the public about completed investigations. Previously, FINMA typically withheld such information, which drew sharp criticism. Early intervention mechanisms would be strengthened to protect bank customers.

Liquidity provisions and next steps

The proposals also include enhanced stabilization and resolution plans for systemically important banks, expanded access to National Bank liquidity, and quantitative minimum requirements for collateralized liquidity access from the National Bank for systemically important and medium-sized banks. Smaller banks are not affected by the liquidity provisions. The consultation runs until November 19, 2026. The Federal Council plans to submit the bill to parliament in 2027, with the new rules taking effect no earlier than the beginning of 2029. Capital requirements, which parliament is currently debating separately, are not part of this package; the Ständerat is scheduled to decide on those in September.