Executive Overview
Open Banking and Open Finance have fundamentally reshaped
regulatory and competitive dynamics across major financial markets.
The European Union introduced a mandatory access-to-account regime
under PSD2, while the United Kingdom developed a centralized Open
Banking entity model. Switzerland, by contrast, has deliberately
refrained from imposing a statutory API-access obligation on
banks.
This regulatory restraint does not, however, equate to legal
simplicity. Swiss Open Finance initiatives operate within a dense
matrix of banking secrecy, data protection, outsourcing regulation,
supervisory expectations and competition law. The absence of
prescriptive legislation shifts complexity from statutory
compliance to contractual structuring and meticulous risk
allocation.
