The Swiss Financial Market Supervisory Authority (FINMA) has identified further progress in UBS’s resolvability and continues to view a resolution as feasible.
However, there is a need for greater optionality, which will also require legislative changes. UBS’s emergency plan largely fulfils the current statutory requirements. However, it needs to be better integrated in the resolution plan in the future and thus cannot currently be regarded as executable.
As in 2024, FINMA’s review of the recovery plan was suspended again this year, owing to the ongoing integration work.
FINMA believes that UBS could at present be recapitalised and resolved using its preferred resolution strategy of continuing as a going concern via the single point of entry bail-in. In its assessment of UBS’s resolvability as at 31 December 2024, FINMA determined that the bank had made further progress in remedying previously identified shortcomings. The bank has achieved significant milestones, particularly with the merger of the parent banks and Swiss units of Credit Suisse (CS) and UBS. The group’s resolvability had therefore improved since the last assessment.
In line with established international practice, FINMA believes that when the Point of Non-Viability (PONV) is met, it should also be possible to implement a solvent market exit and a forced sale of the bank (or parts thereof) in a legally certain manner as well as a restructuring. When there is a threat of insolvency, this enables the authorities to choose the approach that has the best prospect of safeguarding financial stability and maintaining systemically important functions without having recourse to taxpayers’ money or using emergency powers.
However, there are still considerable legal uncertainties surrounding the implementation of these options. FINMA therefore supports the strategy set out in the Federal Council’s parameters for proposed legislation to make the crisis toolbox more flexible and put it on a more secure legal footing. It published an information sheet on this topic in June 2025. Adequate liquidity support is an essential prerequisite for all options.
UBS’s emergency plan is largely compliant with the current requirements of the Banking Ordinance. Nonetheless, the CS crisis and the subsequent investigations have shown that in its current form, the emergency plan of a global systemically important bank (G-SIB) cannot meet the aim of maintaining systemically important functions while also safeguarding financial stability at international level. It therefore needs further development.
This view was confirmed in the Parliamentary Investigation Committee and Federal Council reports on the CS crisis and the Federal Council’s parameters paper. Hence the UBS emergency plan cannot be regarded as executable for the time being.
UBS consolidated its emergency plan with CS’s in the reporting period and began to develop possible approaches to integrating it in the group-wide resolution plan in the context of a solvent market exit.
Due to the ongoing integration of CS within UBS and the resultant rapid pace of change, a full assessment of the bank’s recovery plan was not possible again in 2024. UBS submitted an updated version in the summer of 2025 which is currently under review.
As an internationally active systemically important bank, UBS has to fulfil enhanced crisis planning requirements. FINMA prepares a resolution plan for the entire group that can be implemented if the PONV is met. FINMA reviews the bank’s resolvability annually based on this plan and shares the results with the Financial Stability Board (FSB) as part of its resolvability assessment process for all global systemically 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 sets out the measures the bank would deploy in a crisis to restore stability on a sustainable basis and enable it to continue operating without state intervention. The emergency plan shows how systemically important functions would be maintained if the recovery fails and the resolution is unsuccessful.
