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The Swiss Financial Market Supervisory Authority FINMA today published guidance on the extension of the transitional period for exchange of collateral in certain OTC derivatives transactions. The current transitional period runs until 1 January 2026 and will be extended by a further three years.
AI Analysis
FINMA extended the transitional period for collateral exchange requirements in non-centrally cleared OTC derivatives from January 1, 2026 to January 1, 2029, providing Swiss market participants with three additional years of relief from mandatory collateral posting obligations on certain equity derivatives. This extension aligns Swiss regulation with the EU's indefinite exemption introduced in December 2024, preventing competitive disadvantages for Swiss derivatives traders while a permanent regulatory framework is developed.
Key dates
October 9, 2025
- FINMA Guidance 04/2025 published and takes effect immediately
January 1, 2029
- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted
Suggested considerations
*Acknowledge the extended timeline: Update internal compliance calendars and risk management frameworks to reflect the January 1, 2029 deadline rather than January 1, 2026.
*Monitor FinMIA revision: Track ongoing legislative developments regarding the permanent regulatory framework for OTC derivatives to prepare for post-2029 compliance requirements.
*Assess competitive positioning: Evaluate whether the extended transitional period affects trading strategies, counterparty relationships, or market competitiveness relative to EU and UK peers.
What changed
The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically:
Previous deadline: January 1, 2026
New deadline: January 1, 2029
Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or...
Regulatory basis: FINMA Guidance 04/2025, issued October 9, 2025, under authority granted by Article 131 paragraph 6 FinMIO
The extension does not eliminate the collateral exchange obligation;...