Today, the Federal Council will adopt its proposal for stricter banking regulation and submit it for consultation. For months, the main topic of public debate has been the issue of capital adequacy. However, this discussion falls far short of the mark. The impact of regulation on 100,000 bank employees in Switzerland has been completely ignored.

Everyone agrees: Switzerland must be prevented from finding itself in a situation like that of UBS in 2008 and Credit Suisse in 2023. But what does that mean in concrete terms? What exactly must not happen again?
The Swiss Bank Employees Association is demanding that irresponsible top managers from the Executive Board and Board of Directors be held accountable if they cause a bank to run into difficulties or drive it to the wall. In the future, we will also need supervisory authorities that perform their duties and take action, as well as a Federal Council that supports the supervisory authorities.

1. Holding irresponsible top managers to account

Neither in 2008 nor in 2023 did the irresponsible actions of the Group Executive Board and the Board of Directors have any consequences. This must not happen again in the future.
Bank employees who break the rules feel the consequences immediately. They lose their job immediately. The CEO and the Chairman of the Board of Directors who bring a bank into difficulties or drive it to the wall, negligently ignore risks and defy the instructions of the supervisory authorities remain unchallenged.
Irresponsible actions by the Group Executive Board and the Board of Directors must not be allowed to pay off. Clear responsibilities and personal liability are needed. In addition, the Swiss Bank Employees Association has long been calling for a separate criminal provision for members of boards of directors and group management of banks. The Federal Council resorted to emergency legislation two years ago. It is therefore surely no problem for the Federal Council to apply criminal law much earlier.

2. Supervision that fulfills its responsibilities

The parallels between 2008 and 2023 are also striking in terms of supervision. The Swiss Federal Banking Commission under Director Daniel Zuberbühler failed back in 2008.
Parliament also investigated the role of supervision back then. In its report of 30 May 2010, the Control Committee made it very clear: “In the opinion of the CPC, the main problems regarding the ability of the Swiss authorities to recognize financial market crises in good time are related to the lack of follow-up of their own criticisms or observations and the lack of a critical spirit among all the authorities concerned.” And FINMA stated in its report: “Overall, however, it must be noted that the SFBC did not monitor the implementation of these measures in a sufficiently structured and emphatic manner and thus did not actually demand them. (…) The SFBC thus underestimated the risks posed by the identified deficiencies and therefore proved insufficiently effective in implementing its demands.”
The fact that Mr. Zuberbühler in particular is now appearing as a prominent advocate for a maximum increase in equity seems like a revenge foul for the criticism he had to take for his insufficient persistence in 2008.
We now know that FINMA was also completely inadequate in its supervisory role at Credit Suisse and was part of the problem. Even before the publication of the PUK report, the Swiss Bank Employees Association had already called for the resignation of the FINMA Chairman. Although the PUK report confirmed the Swiss Bank Employees Association’s criticism of supervision, nothing has happened to date. Why is the Federal Council afraid of sending a strong signal that politicians want a strong supervisory authority that is willing to act in the future by appointing a new FINMA Chairman?
In both 2008 and 2023, the supervisory authorities failed to fulfill their responsibilities. This must not happen again in the future. We don’t just need more regulation, we need supervisory authorities that do their job and use the existing instruments. But we also need a Federal Council that backs up the supervisory authorities and doesn’t just make announcements in a crisis situation and demand that Credit Suisse be left alone now.

3. Increase capital requirements with a sense of proportion

No one disputes that UBS’s equity was too low in 2008 in relation to its business model and risks. The requirements were subsequently tightened, but were not applied at Credit Suisse for years with exceptions. In the end, it was simply too late for a correction.
UBS is in a much better position in 2025 – even after the integration of Credit Suisse. It has greatly adapted its business model, has far fewer risks and a significantly higher equity ratio. But Switzerland finds itself in a classic conflict of objectives. On the one hand, Switzerland wants security and to protect itself as effectively as possible against the risks of a new banking crisis. And therefore the demand for the highest possible equity capital.
On the other hand, Switzerland needs a globally active bank. Tens of thousands of jobs are at stake here. But it also makes a big difference for the heavily export-oriented SMEs whether they work with a Swiss bank or an American, British or German bank.
The discussion about capital requirements must therefore be conducted with a sense of proportion. The business model and the risks must be included in the discussion. The impact of measures on the financial center must also be taken into account – at UBS alone, up to 10,000 additional jobs are at risk.
It sounds extremely cynical when professors or the former Chairman of the SFBC act as if the arbitrary increase in capital requirements has no impact and only shrug their shoulders when it comes to the issue of jobs. Since March 2023, the Swiss Bank Employees Association has been talking about the people, the employees affected, while politicians and experts only talk about figures.
UBS must remain a Swiss bank and embody and live Swiss values. This includes the decades-long tradition of a healthy social partnership. Where opinions differ, we must come to an agreement in the interests of our employees. The Swiss Bank Employees Association expects politicians to ensure that the framework conditions allow UBS to remain a Swiss bank and live Swiss values in the future.
The Swiss Bank Employees Association is the voice of bank employees and will focus on the people, the employees in the banks, in the