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Record STMT-W85E3CDAspirational

AI Regulation in Switzerland

Position paper Corporate governanceWestern Europe · CHproposed

This policy paper by SIX outlines recommendations for Switzerland's approach to AI regulation, advocating for a flexible, sector-specific strategy that balances innovation with trust and competitiveness in the financial sector. It proposes implementing the Council of Europe's AI Convention through targeted legislation, aligning with EU standards where feasible, and fostering industry self-regulation. The document emphasizes integrating AI governance into existing supervisory frameworks, such as FINMA's guidelines, rather than creating a comprehensive horizontal AI law.

Summary and content fields are drawn from the document text and are pending editorial review.

Who issued it

Aarhus UniversityAcademic · DK
Lead issuer
Legal forceAspirational
Under whose authorityCorporate governance
Judged fromfull text

Who it governs

National governmentRegulatorsCompaniesAI deployers and users

Policymakers, regulators, and financial industry stakeholders looking to understand and shape Switzerland's evolving AI regulatory framework.

Sectors
Finance and insurance · financial market infrastructure and financial servicesCross-sector

What the document contains

What's covered

The document addresses the strategic direction of AI regulation in Switzerland, identifying current gaps in the legal framework and proposing policy measures across five areas: targeted legislation based on the Council of Europe AI Convention, sector-specific supervision, EU alignment, industry self-regulation, and the preservation of innovation-friendly conditions.

What's missing

The document does not provide a comprehensive, finalized legislative text, binding judicial rulings, or highly detailed technical compliance standards for AI algorithms.

Key takeaways
  • Switzerland should avoid a blanket horizontal AI law and instead pursue a flexible, sector-specific regulatory approach.
  • The Council of Europe’s AI Convention should be implemented via targeted amendments to existing Swiss laws.
  • Financial market regulators like FINMA should integrate AI governance into existing supervisory frameworks without creating new bureaucratic institutions.
  • Switzerland should align key aspects of its AI rules with EU standards to ensure cross-border market access while avoiding an unnecessary Swiss finish.
  • Combining binding legal measures with industry-led self-regulation and standards will help address AI risks effectively while maintaining innovation.
Principles it states
responsible innovation under effective oversighttransparency, fairness, and accountabilitysubsidiarity and technology neutralitysame business, same risks, same rules
Outline
Executive Summary
1. Current Legal Provisions
2. Gaps and Improvement Opportunities in the Current Regulatory Framework
3. Policy Proposals for an AI Framework in Switzerland
   3.1 Implement AI Convention Through Targeted Legislation
   3.2 Strengthen Sector-Specific Approach
   3.3 Ensure Alignment with EU Where Feasible
   3.4 Foster Industry Self-Regulation and Best Practices
   3.5 Preserve Innovation-Friendly Conditions and Trust
4. Conclusion & Path Forward
IssuedSeptember 2025
Length3,334 words · 9 pages
FormatNot recorded
Scopenational

How it scores

Pending review

Each score is backed by a quote verified against the document text. Editorial review has not yet confirmed them.

Accountability

4/5

Clear responsibility for AI outcomes

Law should explicitly state that companies are liable for outcomes of automated systems as if those were human decisions, reinforcing the Convention’s accountability principle.

3.1 Implement AI Convention Through Targeted Legislation

screening score · 2026-10-23

Fairness

4/5

Non-discrimination and equitable treatment

Firms test AI models for disparate impacts on protected groups and mitigate any found bias. This enforces the Convention’s equality and non-discrimination principle in practical terms.

3.1 Implement AI Convention Through Targeted Legislation

screening score · 2026-10-23

Human Dignity

0/5

Respect for the inherent worth of persons

screening score · 2026-10-23

Human Oversight

4/5

Humans remain in control of consequential decisions

Additionally, ensure that individuals have access to legal remedies if they are wronged by AI-driven decisions – for instance, the ability to contest an automated decision (like denial of service) and have it reviewed by a human.

3.1 Implement AI Convention Through Targeted Legislation

screening score · 2026-10-23

Privacy

2/5

Protection of personal data and private life

Building on practices like data protection impact assessments, expect organizations to conduct AI impact assessments.

3.1 Implement AI Convention Through Targeted Legislation

screening score · 2026-10-23

Transparency

4/5

Openness about how AI systems work and are used

Establish provisions ensuring that when AI systems materially influence decisions impacting individuals, those individuals are notified and granted access to pertinent information upon request.

3.1 Implement AI Convention Through Targeted Legislation

screening score · 2026-10-23

Enforcement

3/5

Consequences and compliance mechanisms with real force

Enhance Risk Management Frameworks For critical sectors such as the financial market, AI must be subject to strong risk management frameworks.

Executive Summary

screening score · 2026-10-23

Impact Assessment

4/5

Required assessment of an AI system's risks/impacts before or during use

Building on practices like data protection impact assessments, expect organizations to conduct AI impact assessments.

3.1 Implement AI Convention Through Targeted Legislation

screening score · 2026-10-23

Topics

ai_regulation financial_sector risk_management innovation switzerland