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ARTICLE · 09 OCTOBER 2026

FINMA Consults On Revised Rules For Direct Transmission

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Advestra's legal team, including Prof. Dr. Rashid Bahar, Dr. Sandro Fehlmann, Angelika Kremer, and Dr. Fabian Loretan, provides insights on critical regulatory developments affecting Swiss financial institutions. The firm examines disclosure requirements under the Federal Act on Data Protection (FADP) for internal investigation reports and analyzes proposed amendments to Banking Act regulations concerning systemically important banks.

SwitzerlandFinance and Banking
Rashid Bahar
Rashid Bahar
Sandro Fehlmann
Sandro Fehlmann
Angelika Kremer
Angelika Kremer
Fabian Loretan
Fabian Loretan

On 30 September 2026, the Swiss Financial Market Supervisory Authority FINMA opened a consultation on a partial revision of FINMA Circular 2017/6 “Direct Transmission”. The revision reflects the amendment of article 42c FINMASA that was passed into law by Parliament on 19 June 2026. It aims to strengthen legal certainty for supervised institutions transmitting non-public information directly to foreign authorities and bodies. The consultation runs until 27 November 2026; entry into force is planned for 1 May 2027.

Clearer distinction between transmission purposes

The revised Circular separates transmissions for financial market supervisory purposes under article 42c (1) FINMASA from transmissions under article 42c (3) FINMASA that do not serve such a purpose. Financial market supervision includes licensing, ongoing supervision, enforcement, crisis measures and measures in the event of a risk of insolvency. Authorities acting exclusively in criminal, tax or competition matters are

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