FINMA circulars at a glance: which requirements bind legal and compliance

Short answer: FINMA circulars set out how the Swiss Financial Market Supervisory Authority applies financial market law in its supervisory practice (Art. 7(1)(b) FINMASA). FINMA’s overview (as of 22 April 2025) lists 37 circulars in force. For legal and compliance teams, the key ones cover corporate governance (2017/1, 2017/2), outsourcing (2018/3), operational risks (2023/1), FinSA conduct rules (2025/2) and video identification (2016/7).

This FINMA circulars overview is written for legal and compliance teams at banks, insurers, securities firms and asset managers in Switzerland. It shows which circulars apply to whom, which changes FINMA plans up to 2028 and what capacity implementation requires.

What are FINMA circulars?

FINMA circulars give concrete form to open and undefined provisions of the financial market acts and set out how FINMA exercises its discretion. They bind FINMA itself when it applies the law; it issues its rulings on the basis of the statute and in line with the circular.

• Legal nature: circulars do not need an express basis in a formal statute but must be traceable to a higher-ranking enactment. If that law changes, parts of a circular can become outdated until it is revised.
• Procedure: FINMA consults the parties concerned before issuing a circular.
• Circulars vs ordinances: FINMA also issues ordinances, such as the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA). According to its list of regulatory projects, it is currently moving several circulars into ordinances to put the rules at the appropriate regulatory level.

Because FINMA bases its supervision on them, circulars are in practice the benchmark for institutions’ organisation, internal directives and controls.

Who is affected?

Which circulars apply depends on the licence. FINMA’s addressee list assigns each circular to types of institution; FINMA expressly describes this information as indicative.

Further circulars cover capital, liquidity, accounting, auditing (2025/1) and insurance-specific topics. They usually touch legal and compliance only at the margins.

Deadlines and status of FINMA circulars

The next fixed deadline is 1 January 2027, when banks and insurers in supervisory categories 3 to 5 must comply with the climate-related provisions of circular 2026/1. The other dates come from FINMA’s list of regulatory projects as of 1 September 2026 and are planned dates.

All deadlines, including EU law and Germany, are collected in the regulatory calendar for legal and compliance.

What institutions need to do now

Institutions should know which circulars apply to them, who owns each one and where the gaps are. A proven approach:

1. Build an inventory: use the addressee list to record which circulars apply to your licence.
2. Assign ownership: name a responsible unit in the business, legal or compliance for each circular.
3. Run a gap analysis: compare directives, processes and controls with the requirements and prioritise actions.
4. Track projects: follow FINMA consultations and its list of regulatory projects, especially on circular 2016/7 and AMLO-FINMA.
5. Document implementation: file decisions and evidence so that the audit firm and FINMA can follow them.

Two rules affect the organisation directly. Under circular 2018/3, overall management and core management tasks cannot be outsourced, while operational compliance tasks can. Under Art. 24 AMLO-FINMA, financial intermediaries must designate an anti-money laundering unit; responsibility stays with line management and the executive board. What this means for outsourcing is covered in compliance outsourcing: what can be outsourced and what stays with the company.

Which roles and capacity are needed

Implementing a circular requires expertise in financial market law and project capacity. Typical roles are:

• Regulatory specialist or financial markets legal counsel: analyses requirements and updates directives.
• Compliance officer: sets up controls, trains staff and monitors implementation.
• AML and KYC specialists: adapt onboarding and due diligence, for example after a revision of AMLO-FINMA or circular 2016/7.
• Project lead: coordinates the business, IT, legal and compliance and reports to the executive board.

A short gap analysis can often be handled by one experienced professional working part-time. Large programmes such as a KYC remediation need a team. One example is the case study on a KYC task force of eight compliance officers at a Swiss financial institution.

How interim support helps

Interim professionals close gaps when a circular is new or revised and the team is busy with day-to-day work. They work in the institution’s team; the institution directs the work and remains responsible for implementation.

Alpinum Solutions provides regulatory specialists, compliance officers, AML specialists and lawyers with financial markets experience through staff leasing and freelancing, part-time or full-time. Professionals can also take on formal functions such as the anti-money laundering unit. For the MLRO role, regulatory restrictions may rule out an external mandate or require staff leasing. Selected profiles are usually available within 48 hours; the company and Alpinum agree the start date together.

Frequently asked questions about FINMA circulars

Are FINMA circulars legally binding?

FINMA circulars bind FINMA when it applies the law; they do not bind institutions directly in the way a statute does. In practice they are still decisive: FINMA issues its rulings on the basis of the statute and in line with the circular. Institutions therefore align their organisation, directives and controls with them.

Where can I find the current list of FINMA circulars?

FINMA publishes an overview of current circulars on its website, with a filter by type of institution. It also provides an addressee list as a PDF, last amended on 22 April 2025, and a list of regulatory projects as of 1 September 2026. Check both before any gap analysis.

Which circular governs a bank’s compliance function?

Circular 2017/1 “Corporate governance – banks” requires an internal control system with an independent risk control and compliance function that matches the institution’s size, complexity and risk profile (margin no. 6). It defines compliance as adherence to legal, regulatory and internal rules (margin no. 7). Circular 2017/2 applies to insurers.

What changes when circulars are moved into ordinances?

According to the list of regulatory projects as of 1 September 2026, the circulars on liquidity risks (2015/2), risk diversification (2019/1) and intra-group positions (2013/7) are due to be moved into FINMA ordinances in Q1 2027. For institutions, this means directives and references to the old circulars will need updating.

Do FINMA circulars apply to companies in Germany?

No. FINMA circulars are addressed to institutions under Swiss financial market supervision. Banks and financial services providers in Germany are supervised by BaFin and follow its requirements. Groups with entities in both countries therefore need professionals who know both regimes.

Next step

Alpinum Solutions is the leading provider of interim legal & compliance in Switzerland and provides professionals to implement FINMA requirements. Tell us what you need, and we will show you suitable profiles.

• Regulatory compliance and regulatory change: professionals for regulatory projects
• FINMA circular 2023/1: implementing operational resilience
• Swiss AML revision and transparency register
• Regulatory radar: all articles on regulatory change
• Basel III final and CRR III: implementation workload for legal, risk and compliance
• Discuss your needs

Last updated: 10 November 2026.