Switzerland Intends To Move Towards A Senior Managers Regime

On 6 June 2025, the Swiss Federal Council unveiled a comprehensive package of proposals to strengthen the country's banking regulation in the wake of the Credit Suisse crisis. A central pillar of the proposed reform is the introduction of a Senior Managers Regime (SMR).

1. Senior Managers Regime

Under the proposed regime, banks would be required to assign clearly defined and documented responsibilities to its top-level executives. The focus would be on central functions of the bank and would be limited to the level of senior management (including the board of directors, the executive committee, the heads of control functions and the heads of the main business divisions). The exact scope of individuals subject to the SMR would be determined based on the structure, size and business model of each bank. The assigned responsibilities would have to be appropriately documented, submitted to the Swiss Financial Market Supervisory Authority (FINMA) and updated as required.