A Swiss bank or company entering into an OTC derivative checks whether the counterparty is a small counterparty, whether the trade must be cleared, and where it must be reported. For uncleared trades, it also checks whether collateral must be exchanged.

Position and competent authorities

The core of Swiss derivatives regulation is the derivatives trading chapter of the Financial Market Infrastructure Act (FinMIA; its German abbreviation is FinfraG)1. The Act governs the organization and operation of financial market infrastructures and the conduct of participants in securities and derivatives trading. Its aims are the proper functioning and transparency of the markets, the stability of the financial system, the protection of participants, and equal treatment of investors2.

The derivatives trading chapter requires four things: clearing, reporting to a trade repository, risk mitigation for uncleared trades, and trading on trading venues. Numerical thresholds and detailed scope are set by the Financial Market Infrastructure Ordinance (FinMIO) of the Federal Council (the government) and by FINMA's own Financial Market Infrastructure Ordinance (FinMIO-FINMA)3. The background to the international reforms is covered in The G20 OTC Derivatives Reforms.

FINMA is a public-law institution established by the Financial Market Supervision Act, with its own legal personality. It supervises the financial market under the financial market acts4. Under the FinMIA, it authorizes Swiss financial market infrastructures, recognizes foreign ones, and supervises them5.

The Swiss National Bank (SNB) is Switzerland's central bank. To protect financial stability, it oversees systemically important central counterparties, central securities depositories, and payment systems, and sets special requirements for them6. A systemically important infrastructure is subject to both FINMA supervision and SNB oversight. The two authorities carry out their work jointly, exchange information regularly, and avoid overlaps7.

Item Instrument Articles
Framework of duties Financial Market Infrastructure Act (FinMIA) Articles 93 to 117
Thresholds, risk mitigation, start of duties Financial Market Infrastructure Ordinance (FinMIO) Articles 76 to 114
List of products subject to clearing FINMA Financial Market Infrastructure Ordinance (FinMIO-FINMA) Articles 6 and 7, Annex 1
Status and tasks of FINMA Financial Market Supervision Act (FINMASA) Articles 5 and 6
SNB oversight National Bank Act (NBA) Articles 19 to 21

The legal texts were checked as published on Fedlex on October 23, 2026. The versions are the FinMIA as of February 1, 2024 and the FinMIO as of January 1, 2025. They also include the FinMIO-FINMA as of February 1, 2023, the FINMASA as of April 1, 2025, and the National Bank Act as of September 1, 20238.

Covered transactions and parties

The FinMIA defines a derivative as a financial contract whose value depends on one or more underlying assets and which is not a cash transaction9. The following are not derivatives for the purposes of the derivatives trading chapter10:

  • Structured products such as capital-protected products, capped return products, and certificates
  • Securities lending and borrowing
  • Commodity derivatives that must be physically delivered, cannot be cash-settled at a party's discretion, and are not traded on a trading venue
  • Derivatives issued in the form of a security, and derivatives accepted in the form of a deposit

The chapter applies to financial and non-financial counterparties with their registered office in Switzerland11.

Category Who is included
Financial counterparty Banks, securities firms, insurers and reinsurers, parent companies of financial or insurance groups, asset managers and fund management companies, collective investment schemes, pension schemes and investment foundations
Non-financial counterparty Companies that are not financial counterparties
Parties and counterparties subject only to reporting Multilateral development banks, bodies of the Confederation, cantons, or communes (if not financial counterparties), foreign central banks, the ECB, the EFSF, the ESM, and others
Outside the chapter The Confederation, cantons, communes, the SNB, and the Bank for International Settlements (BIS)

FINMA can subject the Swiss branch of a foreign financial market participant to the chapter if the branch's regulation falls well short of the Swiss requirements12.

A small counterparty is one whose rolling 30-business-day average gross position in outstanding OTC derivatives is below a threshold. Non-financial counterparties have thresholds by category, and financial counterparties have one threshold for all categories combined13.

Party Positions counted Threshold
Non-financial counterparty Credit and equity derivatives CHF 1.1 billion
Non-financial counterparty Interest rate, currency, commodity, and other derivatives CHF 3.3 billion
Financial counterparty All OTC derivatives (at the financial or insurance group level) CHF 8 billion

A party that consolidates a group also counts the group's intra-group transactions. Risk-reducing transactions directly linked to business activity, liquidity management, or asset management are excluded from a non-financial counterparty's calculation14. A counterparty that exceeds a threshold stops being small four months after the day it exceeds it15. A party may rely on its counterparty's declaration of its status unless there are indications to the contrary, and the declaration applies to all duties in the chapter16.

Requirements

Transactions involving a small counterparty are exempt from the clearing duty, and the exchange of collateral does not apply to transactions with a small non-financial counterparty.

Clearing duty

The clearing duty applies to OTC derivatives transactions, meaning those not conducted through a trading venue, in the categories FINMA has designated. The transaction is cleared through a central counterparty that FINMA has authorized or recognized. Transactions with small counterparties, and between small counterparties, are exempt17. FINMA designates categories by looking at the standardization of the contracts, liquidity, trading volumes, the availability of pricing information, and counterparty risk. It cannot designate a derivative that no central counterparty clears18.

The version of the FinMIO-FINMA in force from February 1, 2023, lists the following categories as subject to clearing19.

Type Reference rate or index Currency Term
Basis swaps and fixed-to-floating interest rate swaps EURIBOR Euro 28 days to 50 years
FRAs (forward rate agreements) EURIBOR Euro 3 days to 3 years
OIS FedFunds, SOFR US dollar 7 days to 3 years
OIS €STR Euro 7 days to 3 years
OIS SONIA Pound sterling 7 days to 50 years
OIS TONA Yen 7 days to 30 years
Index credit default swaps iTraxx Europe Main, Crossover Euro Series 17 onward, 5 years

The following transactions need not be cleared20:

  • Transactions concluded before the party stopped being small
  • Intra-group transactions between two parties in the same consolidation, subject to centralized risk management, that do not aim to circumvent the duty
  • Cross-currency swaps and FX forwards whose settlement is guaranteed (PvP)
  • Transactions of a covered bond issuer that hedge interest rate or currency risk and meet conditions such as a collateral ratio of at least 102%
  • Cross-border transactions where the counterparty is based in a jurisdiction FINMA recognizes as equivalent and is not subject to a clearing duty under that country's law

The duty also covers a transaction with a foreign counterparty if that counterparty would itself be subject to the clearing duty were it based in Switzerland21. This applies to Swiss parties subject to the duty. The duty starts in stages after FINMA publishes a category. It starts 6 months later for new transactions between participants of the same central counterparty. It starts 12 months later for transactions between participants and financial counterparties that are not small, among others, and 18 months later for all other new transactions22.

Trade reporting

Derivatives transactions, including exchange-traded ones, are reported to a trade repository that FINMA has authorized or recognized23. The reporting party depends on the status of the parties to the transaction24.

Transaction Reporting party
Between a financial and a non-financial counterparty The financial counterparty
Between two financial counterparties The one that is not small; if both are small or both are not small, the seller
Between two non-financial counterparties The same rules apply by analogy; no report between two small ones
The foreign counterparty does not report The party with its registered office in Switzerland
Centrally cleared transaction The central counterparty; the parties, if a recognized foreign central counterparty does not report

The report is due by the next business day after the transaction is concluded, amended, or terminated. At a minimum it contains the names and seats of the parties, the type of transaction, the maturity, the notional amount, the price, the settlement date, and the currency. The ordinance sets the list of reported fields25. Third parties may be used to report. The supporting documents for a transaction are kept under the retention rules of the Code of Obligations26.

Separately, securities firms and participants in a trading venue report their securities and derivatives transactions to a trading venue. Derivatives on securities admitted to trading on a venue are reported to that venue. This report is used for market surveillance and is a separate duty from reporting to a trade repository27.

Obligation to trade on venues

The Act requires derivatives designated by FINMA to be traded through a trading venue authorized or recognized by FINMA or through the operator of an organised trading facility. Transactions involving small counterparties, cross-currency swaps and FX forwards with guaranteed settlement, and derivatives that no venue admits to trading are exempt. The duty starts 6, 9, or 12 months after FINMA publishes the derivative category, depending on the parties28. The February 1, 2023 version of the FinMIO-FINMA has a list of products subject to clearing but no list of products subject to the trading duty29.

Operational risk mitigation for uncleared trades

Uncleared OTC derivatives are subject to risk mitigation duties. The following are exempt: transactions with parties subject only to reporting or outside the chapter, transactions that are not between companies, cross-currency swaps and FX forwards with guaranteed settlement, and transactions cleared voluntarily30.

The following are required for operational and counterparty risk31.

Duty Content
Confirmation Terms confirmed by both sides within 2 business days of the trade (3 if concluded after 4 p.m.)
Extension of the deadline One more business day for complex transactions and small parties
Portfolio reconciliation Every business day for 500 or more outstanding trades, weekly for 51 to 499, quarterly for 50 or fewer
Dispute resolution Jurisdiction and governing law agreed by the trade date, and a procedure for disputes unresolved after 5 business days
Portfolio compression At least twice a year for 500 or more outstanding trades, where it reduces risk
Mark-to-market Daily valuation at market prices, or by model when no market price is available

Reconciliation is not required for a small non-financial counterparty. Valuation is not required for transactions with a small counterparty.

Collateral and margin

Collateral is exchanged, except by small non-financial counterparties. Parties must be able to segregate collateral from their own assets, and agreements on the direct realization of collateral remain valid in enforcement proceedings and insolvency measures32. Variation margin is calculated every business day from the valuation and paid. Initial margin is exchanged by parties whose month-end average gross position in uncleared OTC derivatives (including FX with guaranteed settlement) for March, April, and May exceeds CHF 8 billion at group level. The duty then applies for the whole following calendar year33.

If the collateral to be exchanged is less than CHF 500,000, the exchange may be waived. The upper limit on the amount by which initial margin may be reduced is CHF 50 million (CHF 10 million for intra-group transactions). Initial margin may be waived for the currency components of currency derivatives34.

The standard initial margin rate depends on the type of derivative and its remaining term. A financial counterparty may calculate it with a market risk model approved by FINMA until an industry-wide standard model is established35.

Type and remaining term Rate
Interest rate, up to 2 years 1%
Interest rate, over 2 and up to 5 years; credit, up to 2 years 2%
Interest rate, over 5 years 4%
Credit, over 2 and up to 5 years 5%
Foreign exchange 6%
Credit, over 5 years 10%
Equity, commodity, and others 15%

Initial margin is calculated for the first time within one business day of the trade and recalculated at least every ten business days. Cash initial margin is held with a central bank or a bank independent of the payer, cannot be offset, and in principle cannot be used for other purposes36. Eligible collateral includes cash deposits, high-quality government and corporate bonds, covered bonds, shares in major indices, gold, and money market funds. Collateral is valued after a haircut, with an additional 8% where the currencies differ37.

Central counterparties and trade repositories

Recognition of a foreign central counterparty requires appropriate regulation and supervision. The foreign authorities must also have no objection to the cross-border activity, undertake to inform FINMA of violations by Swiss participants, and provide FINMA with administrative assistance. For a foreign trade repository, the conditions on regulation and supervision, the absence of objections, and the notification of violations are the same. The last condition is not administrative assistance. Instead, the foreign authorities must confirm two points to the Swiss supervisory authority. First, onward transfer of the data to other foreign authorities is permitted only where mutual legal assistance is possible on transfer to a criminal authority. Second, the Swiss authorities have immediate access to trade repositories in that state38.

On FINMA's list dated October 22, 2026, the authorized Swiss central counterparty is SIX x-clear AG and the authorized Swiss trade repository is SIX Trade Repository AG. The Swiss trading venues are two exchanges, SIX Swiss Exchange and BX Swiss. Among foreign entities, 16 central counterparties are recognized, including LCH Limited, LCH SA, Eurex Clearing AG, CME, ICE Clear Credit, ICE Clear Europe, and Japan Securities Clearing Corporation. Two foreign trade repositories are recognized: DTCC Data Repository (Ireland) and REGIS-TR39.

As checked on October 23, 2026, the SNB names SIX x-clear as Switzerland's systemically important central counterparty. SIX x-clear clears shares, ETFs, and bonds traded on SIX Swiss Exchange and the London Stock Exchange. Among foreign infrastructures, the SNB names LCH Ltd and Eurex Clearing as systemically important for Switzerland. It explains that Eurex Clearing is important as the central counterparty for the Eurex exchange, where derivatives on Swiss underlying assets are traded40.

On April 1, 2017, FINMA authorized SIX Trade Repository AG and recognized REGIS-TR S.A.41 The duties of trade repositories to retain and publish data are covered in Trade Repositories.

Equivalence of foreign law and the EU

A Swiss party is deemed to have met its Swiss duties if it meets them under foreign law that FINMA recognizes as equivalent, or if it trades through a foreign financial market infrastructure that FINMA recognizes42. FINMA recognizes foreign law as equivalent if the derivatives trading duties and the supervisory provisions are comparable in their material effect. For clearing, the condition is that clearing largely reduces the systemic and counterparty risks of standardized OTC derivatives. For reporting, the report must contain at least the minimum information43. Two Swiss parties can use foreign law for a transaction between them only if the transaction or one party has an objective connection with that law. A choice of governing law alone is not a connection.

In its guidance of July 2016, FINMA recognized the clearing, reporting, and risk mitigation provisions of the EU's EMIR as provisionally equivalent. A Swiss party using the EMIR provisions must, except for risk mitigation, use a foreign financial market infrastructure that FINMA recognizes. The guidance says FINMA will decide whether to confirm the provisional recognition in a regular assessment after the EU has finalized its rules44.

On the EU side, the European Commission recognized the supervision of Swiss central counterparties as equivalent in November 2015. A Swiss central counterparty needs ESMA authorization to clear across borders in the EU, and an equivalent supervisory regime is a prerequisite for it45. When FINMA updated the interest rate derivatives subject to clearing in December 2022, it said it had aligned itself closely with EU law46.

Entry into force and transitional measures

Date Event
June 19, 2015 The Financial Market Infrastructure Act is enacted (the ordinance on November 25, 2015)47
January 1, 2016 The FinMIA and the FinMIO enter into force48
April 1, 2017 SIX Trade Repository AG is authorized and REGIS-TR S.A. is recognized, triggering the phased start of reporting49
February 1, 2023 The FinMIO-FINMA enters into force with the updated list of interest rate derivatives subject to clearing50
September 30, 2023 The transitional exemption from the clearing duty for risk-reducing trades of pension schemes and similar bodies ends51
January 1, 2024 Collateral exchange applies to equity derivatives such as equity options52
January 1, 2028 Transitional deadline for reporting outstanding transactions in "all other cases" (July 1, 2028 for transactions through trading venues and similar facilities)53

Pension schemes and investment foundations were exempt from the clearing duty for risk-reducing transactions until September 30, 2023. The exchange of collateral for equity derivatives, such as options on individual equities or on indices, applies from January 1, 2024.

The deadline for reporting outstanding transactions runs from the first authorization or recognition of a trade repository. It is 6 months after that date where the reporting party is not a small financial counterparty or a central counterparty. It is 9 months after that date where it is a small financial counterparty or a non-financial counterparty that is not small. In all other cases the deadline is January 1, 2028. For transactions concluded through a trading venue or the operator of an organised trading facility, each of these deadlines is extended by 6 months. Initial margin was introduced by lowering the group-level threshold in steps, from September 1, 2016, until it reached CHF 8 billion on September 1, 202154.

Examples of the clearing determination

Actual outcomes depend on the terms of each transaction and on how the authorities apply the rules.

YesNoIs the head office inSwitzerland (financialor non-financial), or isit a covered branch?Not subjectNoYesIs the firm or itscounterparty small?Not subjectYesNoIs it an OTC trade, notthrough a trading venue?Not subjectYesNoIs it a category FINMAdesignated for clearing?Not subjectNoYesDoes a legal exception(such as intra-group)apply?Not subjectIf it passes all 5questions, in principlesubject to the clearingduty
Figure 1Is an OTC derivative subject to the clearing duty?
Figure description

There are 5 questions; the second and fifth exit as not subject on "yes", and the other three on "no". The exits, from the top, are outside Swiss law, a small counterparty, a trade through a trading venue, a category FINMA has not designated, and an exception. A transaction that passes all 5 is, in principle, subject to the clearing duty. A Swiss branch that FINMA has subjected to the chapter answers yes to the first question even if its head office is abroad55. Other kinds of exception under question 5, the treatment of foreign counterparties, and the start date of the duty are covered under "Clearing duty" in the text.

Consider a hypothetical example in which Bank A, a Swiss bank, enters into a fixed-to-floating euro EURIBOR interest rate swap, with a remaining term of 5 years, with Company B, a Swiss manufacturer. Bank A is a financial counterparty that is not small. Company B's average gross positions in outstanding OTC derivatives are below the threshold in every category, so it is a small non-financial counterparty.

Because Company B is a small counterparty, the transaction is not subject to the clearing duty. The transaction is between a financial and a non-financial counterparty, so Bank A reports it to a trade repository by the next business day. Because Company B is a small non-financial counterparty, Bank A does not exchange collateral with it.

Suppose Company B's average gross position in interest rate derivatives (excluding hedging transactions) rises to CHF 4 billion, and four months have passed since it exceeded the CHF 3.3 billion threshold. Company B is no longer small, and the same type of swap with Bank A is subject to the clearing duty. The term falls within the 28 days to 50 years for euro EURIBOR fixed-to-floating swaps, so Bank A and Company B clear it through a central counterparty that FINMA has authorized or recognized. The central counterparty reports the cleared transaction to a trade repository.

Suppose the same Bank A and Company B enter into an FX forward in which they exchange US dollar and Swiss franc principal amounts in six months. If settlement is guaranteed, the forward is exempt from the clearing duty, risk mitigation, and the obligation to trade on venues. The reporting duty remains, so Bank A, the financial counterparty, reports it to a trade repository.

Practical points

The procedures for meeting the clearing, threshold, reporting, risk mitigation, and venue trading duties must be set out in writing or in another form that allows proof by text. A non-financial counterparty that decides not to trade derivatives can record that decision in writing and is then exempt from setting out the procedures. A financial counterparty appointed by others to implement their duties also sets out the procedures56.

Compliance is part of the audit, and for non-financial counterparties the auditor reviews whether measures have been taken. If violations are not remedied or are repeated, the auditor reports them to the Federal Department of Finance57. When a counterparty commissions group companies or branches to fulfil its duties, it may exchange the necessary information, including client data, without the client's approval. It may also submit data to a trade repository without its counterparty's approval58.

What this article does not cover

Penalties, the application of FINMA guidance, and the provisions of the FinMIA on exchange listing, disclosure, public takeovers, insider trading, and market manipulation are not covered on this page. Position limits for commodity derivatives are not covered on this page.

This page does not cover whether a version of the FinMIO-FINMA later than February 1, 2023 designates products subject to the trading duty. It also does not cover whether FINMA has confirmed the provisional equivalence of EMIR, whether the EU has recognized Swiss derivatives regulation as equivalent under the third-country provisions of EMIR, or equivalence with the UK. The versions of the ordinance and the Act that Fedlex lists as taking effect in 2027 and 2029 are not covered on this page.

Notes

  1. The English title is "Financial Market Infrastructure Act, FinMIA" (external site), and the title of the German version (external site) is "Finanzmarktinfrastrukturgesetz, FinfraG". FINMA's 2016 guidance abbreviates the Act as FMIA. ↩

  2. FinMIA (external site), Article 1(1) and (2). The derivatives trading chapter is Title 3, Chapter 1 (Articles 93 to 117). ↩

  3. FinMIA (external site), Article 100(4) (the Federal Council sets thresholds) and Article 101(1) (FINMA sets the clearing categories). The preamble of the FinMIO (external site) states that the Federal Council issues it under the FinMIA. ↩

  4. FINMASA (external site), Article 5(1) (public-law institution, own legal personality), Article 1(1)(h) (financial market acts, including the FinMIA), and Article 6(1). ↩

  5. FinMIA (external site), Article 4(1) (authorization), Articles 60 and 80 (recognition of foreign central counterparties and trade repositories), and Article 83(1) and (2) (supervision). The "FINMA's role" section of the FINMA page (external site). ↩

  6. National Bank Act (external site), Article 1(1) (central bank), Article 5(2)(e) (financial stability), and Articles 19 to 21 (oversight). Special requirements are in FinMIA (external site) Article 23. ↩

  7. FinMIA (external site), Article 83(1) and (3). The test for systemic importance is in Article 22(1). ↩

  8. The English texts on Fedlex are reference translations. English is not an official language of the Swiss Confederation, and the translations have no legal force. The German version of the FinMIA (external site) was also consulted. ↩

  9. FinMIA (external site), Article 2(c). ↩

  10. FinMIA (external site), Article 94(3)(a) to (c). Derivatives in the form of securities or deposits are excluded by FinMIO (external site) Article 80. ↩

  11. FinMIA (external site), Article 93(1) to (4) and Article 94(1). Foreign central banks and similar bodies are in FinMIO (external site) Article 79(1) (reporting only). ↩

  12. FinMIO (external site), Article 78. FinMIA (external site) Article 93(5) provides that the Federal Council may subject branches of foreign participants without equivalent regulation. ↩

  13. FinMIA (external site), Articles 98(1), 99(1), and 100(1) and (2). The threshold amounts are in FinMIO (external site) Article 88. ↩

  14. FinMIA (external site), Articles 98(3) and 100(3). Risk-reducing transactions are defined in FinMIO (external site) Article 87, and the average gross position in Article 89. ↩

  15. FinMIA (external site), Articles 98(2) and 99(2). ↩

  16. FinMIA (external site), Article 97(3). FinMIO (external site), Article 83 (the declaration applies to all duties, and changes must be notified). ↩

  17. FinMIA (external site), Article 97(1) and (2). OTC transactions are those not conducted through a trading venue (Article 97(1)). ↩

  18. FinMIA (external site), Article 101(1) and (3). FINMA determines the categories when it authorizes or recognizes a central counterparty (FINMA ordinance (external site), Article 7(1)). ↩

  19. FinMIO-FINMA (external site), Annex 1 (amended December 8, 2022, in force February 1, 2023). Contracts with options are not included. ↩

  20. FinMIA (external site), Articles 103 and 101(3)(b); FinMIO (external site), Articles 84, 86(1) and (3), and 90. Central risk management for intra-group transactions is in Article 91. ↩

  21. FinMIA (external site), Article 102. ↩

  22. FinMIO (external site), Article 85(a) to (c). ↩

  23. FinMIA (external site), Article 104(1). ↩

  24. FinMIA (external site), Article 104(2) to (4). FinMIO (external site) Article 92(2) assigns the report on cleared venue-traded transactions to the party closest to the central counterparty in the chain. ↩

  25. FinMIA (external site), Article 105(1) to (3). FinMIO (external site), Article 93 (the reported fields are in Annex 2). ↩

  26. FinMIA (external site), Articles 104(5) and 106. ↩

  27. FinMIO-FINMA (external site), Articles 2 and 5(3). The content of derivatives reports is described in FINMA's press release of December 14, 2022 (external site). ↩

  28. FinMIA (external site), Articles 112 and 113; FinMIO (external site), Article 108 (6, 9, and 12 months). ↩

  29. The chapters and Annexes 1 and 2 of the FinMIO-FINMA (external site) (Annex 1 lists products subject to clearing; Annex 2 repeals and amends other legislation). FINMA's 2016 guidance (external site) did not cover the trading duty because it was not urgent. ↩

  30. FinMIA (external site), Article 107(1) and (2); FinMIO (external site), Article 94(1). ↩

  31. FinMIA (external site), Articles 108 and 109. FinMIO (external site), Articles 95 to 99. Cross-currency swaps and FX forwards with guaranteed settlement are not counted in the number of trades for reconciliation. ↩

  32. FinMIA (external site), Article 110(1) to (3). The intra-group exemption is in Article 111. ↩

  33. FinMIO (external site), Article 100(1) to (3) (definitions of variation and initial margin; CHF 8 billion). ↩

  34. FinMIO (external site), Article 100a(1) and (2) and Article 100b(1) and (3). The special rule for covered bond issuers is in Article 100a(3). ↩

  35. FinMIO (external site), Article 103(1), (2), and (5). The netting set calculation is in paragraph 4 and Annex 3. ↩

  36. FinMIO (external site), Article 101(1), Article 101a(1), and Article 102(1) to (4). ↩

  37. FinMIO (external site), Article 104(1) and Article 105(1) and (2). Haircuts are in Annex 4. ↩

  38. FinMIA (external site), Article 4(1), Article 60(1) and (2)(b)(3) (conditions for recognizing a central counterparty), Article 80(1) and (2)(b)(3) (conditions for recognizing a trade repository), and Article 78(1)(b) and (c) (content of the confirmation for a trade repository). A central counterparty is defined in Article 48. ↩

  39. FINMA list (external site), "Authorised Swiss ...", "Recognised foreign central counterparties", and "Recognised foreign trade repositories" (dated October 22, 2026). ↩

  40. SNB page (external site) (checked October 23, 2026), "Systemically important financial market infrastructures in Switzerland" and "Foreign systemically important financial market infrastructures". ↩

  41. FINMA Guidance 02/2017 (external site) (April 3, 2017), sections 1 and 2. The recognition was limited to the receipt of reports under the FMIA. ↩

  42. FinMIA (external site), Article 95. ↩

  43. FinMIO (external site), Article 81(1) to (3). The conditions for the risk mitigation and trading duties are in paragraph 2(c) and (d). ↩

  44. FINMA Guidance 01/2016 (external site) (July 6, 2016), sections 2.1 and 2.2 (EMIR Articles 4, 9, and 11). ↩

  45. FINMA press release (external site) (November 13, 2015). ESMA authorization is also required. ↩

  46. FINMA press release of December 14, 2022 (external site). ↩

  47. The date of enactment at the head of the FinMIA (external site) (June 19, 2015) and of the FinMIO (external site) (November 25, 2015). ↩

  48. FINMA Guidance 01/2016 (external site), introduction (entry into force on January 1, 2016). FinMIO (external site), Article 135. ↩

  49. FINMA Guidance 02/2017 (external site), introduction and sections 1 and 2. The start of reporting is in FinMIO (external site), Article 130(1). ↩

  50. FINMA press release of December 14, 2022 (external site). Footnote to Annex 1 of the FinMIO-FINMA (external site) (in force February 1, 2023). ↩

  51. FinMIO (external site), Article 133(1), (1bis), and (1ter). ↩

  52. FinMIO (external site), Article 131(5bis). ↩

  53. FinMIO (external site), Article 130(1)(a) to (c). The first authorization and recognition took place on April 1, 2017 (FINMA Guidance 02/2017 (external site)). ↩

  54. FinMIO (external site), Article 131(5)(a) to (e) and (5bis). The exemption for pension schemes and similar bodies is in Article 133. ↩

  55. FinMIO (external site), Article 78 (where FINMA may subject a Swiss branch of a foreign counterparty to the derivatives trading chapter). ↩

  56. FinMIO (external site), Article 113(1) to (3). ↩

  57. FinMIA (external site), Articles 116 and 117; FinMIO (external site), Article 114. ↩

  58. FinMIA (external site), Article 96; FinMIO (external site), Articles 82 and 92(4). ↩