Switzerland: Financial Sector Assessment Program-Technical Note on Macroprudential Policy and Real Estate Risks
IMF Staff Country Reports, November 13, 2025
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Bibliographic details
- Published: November 13, 2025
- Series: IMF Staff Country Reports
- DOI: https://doi.org/10.5089/9798229027717.002
Institutional setup and mandate shortcomings
- The institutional setup for macroprudential policy in Switzerland is unchanged since the 2019 FSAP.
- The SNB oversees macroprudential matters and makes Countercyclical Capital Buffer (CCyB) proposals but lacks voting power on CCyB decisions.
- Neither the SNB nor FINMA, nor any existing inter-agency committee, hold a formal mandate to recommend adjustments to the Swiss macroprudential toolkit when current tools prove inadequate for addressing systemic risks.
- The absence of a formal mandate to propose toolkit adjustments creates an inaction bias.
Key findings on governance and risks
- Lack of a formal recommending authority for toolkit adequacy:
- No entity currently has a formal mandate to recommend changes to macroprudential tools when they are inadequate for addressing systemic risks.
- Decision-making gap in CCyB governance:
- The SNB can propose CCyB adjustments but does not have voting power on CCyB decisions.
- Consequences identified:
- An inaction bias that can weaken timely responses to systemic risks, particularly in the real estate and mortgage sectors.
Policy recommendations
- Establish a dedicated macroprudential committee:
- The committee should be chaired by the SNB.
- The committee should discuss and jointly decide on macroprudential policies.
- Roles and expected benefits of the dedicated committee:
- Improve macroprudential communication.
- Enhance public accountability for macroprudential decisions.
- Mitigate inaction risks arising from the current mandate and governance gaps.
- Advise relevant agencies on the adequacy of the macroprudential toolkit and necessary changes.
Thematic coverage and subject areas
- Subjects addressed:
- Countercyclical capital buffers
- Financial institutions
- Financial regulation and supervision
- Financial sector policy and analysis
- Financial sector stability
- Loans
- Macroprudential Policy
- Mortgages
Source: International Monetary Fund — Switzerland: Financial Sector Assessment Program-Technical Note on Macroprudential Policy and Real Estate Risks (November 13, 2025).
Content in this bundle
- Executive Summary