FINMA launches consultation on the partially revised Circular 2019/2 “Interest rate risks – banks”

For compliance, risk and treasury teams, this is an early signal that FINMA may adjust expectations around interest rate risk in the banking book, including identification, measurement, governance and reporting. The consultation runs until 15 January 2027 and no final rules have yet been issued, so firms should avoid premature overreaction but should not wait for final publication to begin review. Banks with Swiss operations should assign ownership, map current IRRBB controls and model documentation against the revised text, assess scenario and assumption changes, and prepare a consultation response where material.

Cross-border groups should coordinate Swiss entity input with group ALM and regulatory change teams. The principal business risk is remediation cost and model/process change; the opportunity is stronger ALM governance and clearer supervisory engagement.