Charitable foundations and foundation supervision in Zurich

The Swiss foundation sector

Switzerland has one of the densest foundation sectors in the world. At the end of 2024 there were 13,724 charitable foundations, with total assets of approximately CHF 100 billion. In 2024 298 new foundations were created and a record 268 were liquidated. The sector has about six times as many foundations per capita as the United States or Germany.¹ By the end of 2025 the number had risen to a new record of 13,782, with 325 new foundations and 253 liquidations during the year. The average density stood at 15.1 foundations per 10,000 inhabitants, with Basel-Stadt at the top with 42.9, followed by Zug with 34.2.²

The canton of Zurich had 2,212 charitable foundations at the end of 2024, more than any other canton. Zurich also led in absolute terms in the creation of new foundations in 2024, with 44, just ahead of Geneva with 43.³ Many of the largest Swiss foundations have their seat in Zurich, including foundations established by industrial families, banks and insurance companies. For the Zurich financial centre, charitable foundations matter in two ways. They are clients of the banks and asset managers, whose endowments must be invested prudently and, increasingly, in line with their purpose. They are also a standard element of the succession planning of wealthy families, who often dedicate part of their wealth to philanthropy during their lifetime or at death.

Supervision: from the BVS to ATIOZ

Charitable foundations are supervised by the Confederation if their purpose extends to the whole of Switzerland or abroad, and otherwise by the canton or municipality to which they belong by their purpose. More than a third of all Swiss charitable foundations are supervised by the Federal Foundation Supervisory Authority in Berne.⁴ For the canton of Zurich, supervision of foundations with a cantonal or regional purpose was exercised for many years by the BVG- und Stiftungsaufsicht des Kantons Zürich (BVS), an independent public-law institution that also supervised occupational pension funds. Since 1 January 2026 this task has passed to a new intercantonal institution. The BVS was merged with the Eastern Switzerland pension supervisory authority based in St Gallen to form ATIOZ, the BVG- und Stiftungsaufsicht Tessin, Ostschweiz und Zürich, a public-law institution with its seat in Zurich.⁵

ATIOZ supervises occupational pension institutions in nine cantons: Zurich, Appenzell Ausserrhoden, Appenzell Innerrhoden, Glarus, Graubünden, Schaffhausen, St Gallen, Ticino and Thurgau. Its highest body is a concordat council composed of one representative of the government of each participating canton, which elects an administrative council responsible for strategic and financial leadership.⁶ For classic foundations the scope is narrower. ATIOZ supervises classic foundations in the cantons of Zurich, St Gallen, Ticino and Thurgau. Its supervision ensures that foundations use their assets in accordance with their purpose. It collects periodic reports, examines statutes and regulations for compliance with the law, approves amendments of the organisation or purpose, and may issue recommendations, warnings, fines, directives and suspensions in case of violations.⁷ The merger is part of a broader trend towards the consolidation of supervisory authorities in Switzerland, which aims at professionalisation and economies of scale. For foundations in Zurich, the practical change is limited, because the supervisory staff and the address remain in Zurich.

The reform of foundation law in force since 1 January 2024

The foundation law of the Civil Code was revised by the Federal Act of 17 December 2021, based on parliamentary initiative 14.470 of Council of States member Werner Luginbühl, which aimed to strengthen Switzerland as a location for foundations. The revision entered into force on 1 January 2024.⁸ Its main elements concern four points. Article 84(3) of the Civil Code now codifies the foundation supervisory complaint, which allows beneficiaries, creditors, the founder, co-founders and members of the board with a legitimate interest to complain against acts and omissions of the foundation’s organs. Article 86a extends the right of the founder, which since 2006 has covered changes of purpose, to changes of organisation, subject to a waiting period of ten years since the establishment of the foundation or since the last change. Article 86b relaxes the conditions for immaterial amendments of the foundation deed, which now require only objectively justified reasons, provided no third-party rights are affected. Article 86c clarifies that amendments ordered by the supervisory authority do not require a notarial deed.⁹

The reform was modest in comparison with the original initiative, which had also proposed tax incentives for donors and foundations. It has nonetheless improved the flexibility of the Swiss foundation, particularly for founders who wish to retain some influence over the future development of their foundation. The founder’s right to amend the organisation, for example, allows a family to reorganise the board of a foundation after the founder’s children have grown up, within the ten-year rhythm set by the law. The supervisory complaint gives beneficiaries and board members a clear procedural route when they believe that the foundation is being mismanaged.

Zurich tax practice for charitable foundations

The canton of Zurich has also adjusted its tax practice. On 9 February 2024 the cantonal tax office published changes affecting charitable foundations. Appropriate remuneration of board members no longer stands in the way of tax exemption. The tax office now admits entrepreneurial funding models such as impact investments under certain conditions, and charitable activities abroad are treated on the same footing as domestic activities.¹⁰ These changes respond to long-standing demands of the foundation sector, which had argued that the requirement of unpaid board service made it difficult to recruit qualified board members, and that the restrictive treatment of foreign activities disadvantaged internationally active foundations. The Swiss Foundation Report cited the Zurich reform as an example of how targeted cantonal measures can strengthen the sector.¹¹

Notes

SwissFoundations, “Der Schweizer Stiftungsplatz bleibt stabil – Preview Stiftungsreport 2025”, https://www.swissfoundations.ch/aktuell/preview-stiftungsreport-2025/. ↩
SwissFoundations, “Zahlen & Fakten”, https://www.swissfoundations.ch/stiftungssektor/zahlen-fakten/. The figures come from the annual Swiss Foundation Report, published jointly by SwissFoundations, the Center for Foundation Law at the University of Zurich and the Center for Philanthropy Studies at the University of Basel. ↩
Center for Philanthropy Studies (CEPS), SwissFoundations and Center for Foundation Law, Der Schweizer Stiftungsreport 2025, CEPS Forschung und Praxis vol. 33, p. 9, https://www.swissfoundations.ch/wp-content/uploads/2025/05/24064_Sf_Rap.-25_D_DEF_1.pdf; for the figures on new foundations, SwissFoundations, Preview Stiftungsreport 2025, URL as above. ↩
Der Schweizer Stiftungsreport 2025, p. 14, URL as above. ↩
ATIOZ, home page, https://www.atioz.ch/de/. ↩
ATIOZ, “Über uns”, https://www.atioz.ch/de/ueber-uns/. ↩
ATIOZ, “Klassische Stiftungen”, https://www.atioz.ch/de/klassische-stiftungen/. ↩
LAW.CH, “Schweizer Stiftungsstandort: Neue Stärkungsregeln ab 01.01.2024 in Kraft”, LAWNEWS, November 2023, https://law.ch/lawnews/2023/11/schweizer-stiftungsstandort-neue-staerkungsregeln-ab-01-01-2024-in-kraft/. ↩
SwissFoundations, “Neues Stiftungsrecht tritt am 1. Januar 2024 in Kraft – Die Änderungen auf einen Blick”, https://www.swissfoundations.ch/aktuell/neues-stiftungsrecht-auf-einen-blick/. ↩
Der Schweizer Stiftungsreport 2025, pp. 20–21, URL as above, quoting the practice change: “Neu steht einer angemessenen Entschädigung von Stiftungsrät:innen gemeinnütziger Stiftungen bei einer Steuerbefreiung nichts mehr entgegen.” ↩
SwissFoundations, Preview Stiftungsreport 2025, URL as above. ↩

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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