Swiss capital and liquidity ordinance changes from January 2027

Two Federal Council ordinances set detailed prudential rules for Swiss banks: the Capital Adequacy Ordinance on capital and the Liquidity Ordinance on liquidity. On 22 April 2026 the Federal Council amended both as part of its package on banks that are too big to fail, with effect from 1 January 2027 (Federal Council (external site)).

The capital change concerns software that a bank records as an asset. The liquidity change concerns the information a bank provides to the authorities when it faces a liquidity shortage (explanatory report (external site)).

For systemically important banks, software gets a maximum prudential amortisation period of three years, in line with EU rules (Federal Council (external site)). Prudential amortisation is the write-down used for capital purposes, so after three years software no longer supports capital, even where the accounts write it off more slowly.

As an example only: software that cost CHF 30 million and is written off over six years in the accounts still shows CHF 15 million on the balance sheet after three years. For capital purposes, under a three-year limit as in the amended ordinance (external site), its value would already be zero.

A transition period of two years applies to the treatment of software (Federal Council (external site)). The Federal Council dropped the proposal to require full backing with CET1 capital for software and for deferred tax assets, and dispensed with the change on deferred tax assets for the time being (Federal Council (external site)).

In the Liquidity Ordinance, the new requirements on providing information in the event of liquidity shortages are limited to systemically important banks (Federal Council (external site)).

Both changes apply to systemically important banks in Switzerland (Federal Council (external site)). The roles most directly concerned:

• Capital Reporting Analyst: applies the three-year prudential amortisation to software in the capital calculation.
• Regulatory Reporting Analyst: reflects the new software treatment in capital returns from 2027.
• Liquidity Risk Analyst: prepares the liquidity information the authorities can request during a shortage.
• Liquidity Reporting Analyst: supplies data for the new information requirements.
• ALM Analyst: includes the software effect in capital and balance sheet projections.

The amendments were adopted on 22 April 2026 and take effect on 1 January 2027 (explanatory report (external site)). The two-year transition for software runs from that date (Federal Council (external site)).

A further consultation on the Banking Act and the Liquidity Ordinance opened on 12 August 2026 and runs until 19 November 2026 (Federal Council (external site)). For the Liquidity Ordinance, it proposes requirements that apply from 2033 (Federal Department of Finance (external site)).

The Capital Adequacy Ordinance has included the final Basel III standards since 2025 (Federal Council (external site)). A 2022 revision of the Liquidity Ordinance, in force since 1 July 2022, raised liquidity requirements for systemically important banks (Federal Council (external site)).

The April 2024 report of the Federal Council on banking stability set out the measures behind both amendments (report (external site)).