In a recent decision 7B_544/2026 dated 13 October 2026 and intended for publication, the Federal Supreme Court ("FSC") held that Art. 167a of the Swiss Civil Procedure Code ("CPC"), which has applied since 1st January 2025 and allows a party to refuse to produce documents relating to the activity of its in-house legal department in civil proceedings, does not apply by analogy in criminal or administrative criminal proceedings.