FINMA finds PostFinance’s crisis alternatives incomplete after capital shortfall is addressed

PostFinance has met its additional loss-absorbing-capital requirements, but its emergency plan still falls short of FINMA’s standards. The regulator’s 14 October assessment of plans submitted in 2025 identifies unfinished alternatives for maintaining critical functions if restructuring and continued operation of the bank are not possible.[1]

Zürcher Kantonalbank and Raiffeisen passed the emergency-plan assessment. All three institutions received approval for their recovery plans. PostFinance’s unresolved alternatives must also accommodate its statutory universal-service mandate; a Postal Services Act amendment intended to reduce related legal uncertainty is in consultation.[1]

The comparison with the previous assessment is revealing. In August 2025, FINMA identified both insufficient recapitalisation capacity at PostFinance and an inadequate alternative strategy. It said the bank was building the necessary capital through the end of that year. The latest finding therefore shifts attention from the size of the capital buffer to what can actually be done during a crisis.[2][1]

Recovery and emergency plans answer different questions. Under FINMA’s framework, recovery concerns the bank stabilising itself without government intervention. An emergency plan addresses uninterrupted delivery of functions essential to the Swiss economy, particularly domestic deposits, lending and payments. Resolution concerns restructuring or liquidation through official intervention. Keeping those stages separate explains how a bank’s recovery plan can be approved while its emergency arrangements remain incomplete.[3]

FINMA applied revised recovery criteria for the first time in this assessment cycle, including annual stress exercises involving management and decision-making bodies. Documentation of exercises and crisis communications still need work. The regulator also cautions that meeting domestic-bank requirements cannot ensure continuity in every severe scenario.[1]

For firms depending on a bank’s payment services, the relevant consequence is continuity of cash movement. Deposits remaining recorded at a bank and payments continuing to flow are separate operational questions. FINMA’s definition of critical functions makes that distinction explicit; a broker’s contingency arrangements need to identify which banking services its own customers and funding processes depend on.[3]

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