The Swiss financial market supervision (FINMA) has identified further progress in the resolution of UBS and continues to consider the resolution possible.
However, there is a need for greater justice, which will also require legislative changes. UBS Emergency Plan greatly fulfills current legal requirements. However, it must be better integrated into the future resolution plan and therefore cannot be considered executable.
Like 2024, the Finma review of the recovery plan was resurrected again this year, due to continued integration work.
Finma believes that UBS could currently be recapitalized and resolved using the preferred resolution strategy of continuing as a continuing concern through the single input warranty point. In its assessment of the resolution of UBS on December 31, 2024, Finma found that the bank had made further progress in restoring the previously identified shortages. The bank has achieved significant milestones, in particular with the merger of parental banks and Swiss Credit Suisse (CS) and UBS. Therefore, the solubility of the group was improved by the latest evaluation.
According to established international practice, Finma believes that when the Ponv is fulfilled, it should also be possible to apply a solvent market and a forced sale of the bank (or their components) in a legally defined way as well as restructuring. When there is an insolvency threat, this allows the Authorities to choose the approach that has the best prospect of protecting financial stability and systematically maintain significant functions without resorting to taxpayers’ money or using emergency powers.
However, there are still significant legal uncertainties that surround the implementation of these options. As a result, Finma supports the strategy defined in the parameters of the Federal Council on proposed legislation to make the crisis toolbox more flexible and to put it on a safer legal basis. Published a sheet of information on this issue in June 2025. Adequate liquidity support is an essential prerequisite for all options.
UBS Emergency Plan is largely complying with the current requirements of the banking decree. Nevertheless, the CS crisis and subsequent research has shown that in its current form, the emergency plan of a global systematically important bank (G-SIB) cannot respond to the purpose of maintaining systematically important functions, while protecting economic stability internationally. Therefore, further growth is needed.
This view was confirmed by the Committee on Parliamentary Research and the Federal Council’s reports on the CS crisis and the document of the Federal Council parameters. Therefore, UBS emergency plan cannot be considered as executable at present.
UBS consolidated the emergency plan with the CS during the reference period and began developing possible approaches to integrate it into a resolution plan throughout the team as part of an exit of the solvent market.
Due to the continued integration of CS into the UBS and the resulting rapid change rate, the full assessment of the bank’s rehabilitation plan was not again possible in 2024. UBS submitted an update in the summer of 2025, which is under consideration.
As internationally actively active bank, UBS must fulfill improved crisis planning requirements. FINMA prepares a analysis plan for the whole group that can be applied if the Ponv is met. FINMA examines the bank resolution annually on the basis of this plan and shares the results with the Financial Stability Council (FSB) as part of the evaluation process of choice for all worldwide systematically important banks.
In addition, UBS prepares a recovery plan and an emergency plan. Both are also evaluated by Finma on an annual basis. The recovery plan defines the measures that the bank will develop in a crisis to restore stability on a sustainable basis and will allow it to continue operating without state intervention. The emergency plan shows how important functions will be systematically maintained if recovery fails and the analysis is unsuccessful.