New TBTF rules mandate collateral prep for bank liquidity access
The Swiss Federal Council proposed measures to strengthen too-big-to-fail regulations following the Credit Suisse crisis. Systemically important and medium-sized banks must prepare collateral to access central bank liquidity support under a draft ordinance.
Pledging assets for emergency cash
The Swiss Federal Council presented proposed updates to the country's banking regulation framework on August 12, 2026.
Designed to address regulatory weaknesses exposed by the Credit Suisse crisis, the draft Liquidity Ordinance requires systemically important and medium-sized institutions to prepare sufficient collateral for central bank liquidity access.
To receive emergency support from the Swiss National Bank, institutions must demonstrate the capacity to seamlessly transfer assets as collateral.
Furthermore, the central bank encouraged financial institutions to complete preparations for joining the Extended Liquidity Facility, which becomes operational in early 2027.
Closing loopholes after Credit Suisse
The reform package goes beyond liquidity requirements to target broader systemic risks in the Swiss banking sector.
Key proposals include enhanced stabilization planning and resolvability guidelines for systemically relevant banks, expanded early intervention powers for regulator FINMA, and improved cooperation among regulatory authorities during financial crises.
Combined with measures announced on April 22, 2026, the framework aims to permanently repair structural flaws in Swiss financial regulation.
Necessary progress, incomplete protection
Mandating pre-positioned collateral is a vital technical fix after the Credit Suisse crisis exposed unbacked liquidity gaps.
Yet, structural safety relies heavily on FINMA enforcing early intervention powers aggressively.
Without higher capital requirements, liquidity rules alone cannot end the too-big-to-fail hazard.