FINMA Consultations

Key dates

2025-11-26

FINMA published its ex-post evaluation of Circular 2019/2, identifying potential improvements to proportionality and validation requirements and announcing a planned partial revision.

2026-11-04

FINMA launched the consultation on the partial revision of Circular 2019/2.

2027-01-15 Deadline

The FINMA consultation period closes; consultation responses should be submitted by this date.

Suggested considerations

• Banks should review the consultation package and consider submitting comments to FINMA by 15 January 2027, particularly on proportionality, validation burden, earnings-risk metrics and implementation timing.
• Risk and finance teams should perform an impact assessment using the Basel Committee’s July 2024 recalibrated shock methodology, including the potential effect of 25-basis-point rounding and updated historical calibration data.
• Banks should map current interest-rate-risk models, independent validation procedures and model governance against the expected clarification of minimum validation requirements.
• Compliance teams may wish to reassess whether the institution’s proportionality framework appropriately differentiates requirements by size, business model, complexity and risk profile, while retaining evidence supporting those judgments.
• Treasury and risk functions should assess whether existing interest-rate-risk reporting captures both economic-value effects and effects on net interest income or other relevant revenue measures.
• Governance bodies should record the consultation assessment, scenario-analysis results, model changes and any decision to submit industry comments, while continuing to apply the currently effective Circular 2019/2 until a final revision enters into force.

What changed

The proposed revision would update the standardised interest-rate shock scenarios used to measure interest-rate risk in the banking book, reflecting the Basel Committee’s July 2024 recalibration. The Basel recalibration uses updated historical data, a 99.9th-percentile shock-factor methodology and shock values rounded to 25 basis points; the Basel standard contemplated implementation from 1 January 2026, but the Swiss implementation timeline will depend on FINMA’s final circular.