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A regulatory calendar for practitioners

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The density of recent reforms requires Geneva practitioners to follow a tight calendar. The following table summarises the main deadlines as they emerge from the sources consulted, flagging the dates that remain uncertain.

DateDeadline
1 January 2020entry into force of the Financial Institutions Act and the Financial Services Act
31 December 2021expiry of the period for implementing the requirements of the Financial Services Act
31 December 2022expiry of the transitional period for authorisation applications by asset managers and trustees
1 January 2025entry into force of the final version of Basel III
26 September 2025adoption of the Act on the Transparency of Legal Entities and of the revision of the Anti-Money Laundering Act
1 October 2026entry into force of the transparency register regime
to be confirmedentry into force of the obligations of advisers under the revised Anti-Money Laundering Act

The dates of 2020, 2021 and 2022 emerge from the sources cited earlier in this chapter. That of 1 January 2025 is mentioned by the Fondation Genève Place Financière, while those of 2025 and 2026 relating to the transparency register come from the Federal Council’s press release and from the publications of law firms.1 The date of entry into force of the provisions relating to advisers was expected for mid-2026 according to a publication of October 2025, so that the FATF could take them into account in its next evaluation of Switzerland, and still has to be verified.2

Beyond these deadlines, several projects remain open: the reforms following the Credit Suisse crisis, the regulation of crypto-assets and digital assets, sustainability requirements, the revision of the rules on the assets of politically exposed persons and the development of relations with the European Union. Practitioners must organise permanent regulatory monitoring and anticipate the adjustments that will be needed.

Notes

  1. PwC Switzerland, “Paquet de services LEFIN”; Allnews, 16 October 2025; Federal Council, press release of 15 October 2025; Bonnard Lawson, June 2026 (all accessed September 2026). ↩
  2. “Blanchiment d’argent en Suisse : nouvelles obligations du conseiller” (Money laundering in Switzerland: new obligations of the adviser), Croce & Associés, 20 October 2025. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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