Swiss regulator again finds PostFinance emergency plans incomplete

The universal-service obligation gives PostFinance’s emergency plan a distinctly Swiss complication. The bank cannot plan only for balance sheets, creditors and corporate restructuring. FINMA said its statutory duty to provide universal service must also be taken into account when the bank’s future becomes uncertain.

That obligation links a financial crisis to everyday access. PostFinance’s role sits within the wider Swiss postal and public-service network, making the continuity of essential banking functions a regulatory concern beyond the institution itself. FINMA did not specify which services would be prioritised or how they would be delivered in the worst-case scenario. The regulator said a proposed amendment to the Postal Services Act, currently under consultation, should reduce legal uncertainty.

The legislative process therefore has a direct bearing on crisis planning. Clearer rules could help determine which services must continue, who would be responsible for them and how authorities would manage the transition if PostFinance could no longer operate in its existing form. Until that framework is settled, the bank must work with obligations whose practical meaning remains partly unresolved.

FINMA’s finding does not say that PostFinance has failed its capital test. It shows that the public-service dimension remains insufficiently specified in the event of a full-scale resolution scenario.

FINMA’s review leaves PostFinance with a clear supervisory task while the wider Swiss too-big-to-fail framework continues to evolve. The bank must further specify its options for a scenario in which restructuring and continued operation are no longer possible. The authority also expects improvements in crisis-exercise records and communication planning across the revised requirements.

The latest findings come with an important limitation. FINMA said that approving or assessing the plans does not guarantee the continuation of systemically important functions in every conceivable crisis. The three domestic systemically important banks have smaller financial buffers than globally active institutions. In an especially severe shock, that could restrict the choices available to management and authorities.

The next major regulatory update will concern UBS. FINMA said it intends to provide separate information on the globally active bank’s crisis planning in late autumn 2026. That assessment will add another test of how Switzerland applies the lessons of the Credit Suisse collapse to institutions with different sizes, structures and public responsibilities.

For PostFinance, the immediate issue is precision. FINMA has recognised stronger capital resilience and progress in the alternative strategy. The bank must now show, in operational terms, how essential services would be handled when ordinary recovery tools no longer work.