The automatic exchange of information

The adoption of the global standard

FATCA had shown that automatic reporting of foreign accounts was technically feasible. In 2013 and 2014 the OECD, supported by the Group of Twenty, developed a multilateral counterpart, the Common Reporting Standard, under which financial institutions identify accounts held by persons resident in partner states and report them to their own tax authority, which transmits the data annually to the states of residence. Switzerland, which had long argued for withholding taxes as an alternative, decided to participate. The Federal Council’s report on financial market policy of December 2012 had already acknowledged that international pressure increasingly favoured automatic exchange and that the withholding tax model was losing support.¹

On 18 December 2015 the Federal Assembly adopted the three legal instruments on which the Swiss system rests: the Convention on Mutual Administrative Assistance in Tax Matters of the Council of Europe and the OECD, the Multilateral Competent Authority Agreement on the automatic exchange of financial account information, and the Federal Act on the International Automatic Exchange of Information in Tax Matters. The Federal Council adopted the implementing ordinance on 23 November 2016. The legal basis entered into force on 1 January 2017.² The AEOI Act is published in the classified compilation of federal law as SR 653.1.³ With the European Union, the exchange rests on a separate bilateral agreement that replaced the savings tax agreement and covers all twenty-seven member states.⁴

The Swiss system distinguishes between reciprocal partner states, temporarily non-reciprocal states that provide data but do not yet receive it because they do not meet the standard’s requirements on confidentiality and data security, and permanently non-reciprocal states that provide data but never receive it. Each new partner state is designated by a decision of the Federal Assembly, which gives Parliament a measure of control over the geographic extension of the regime. In September 2026, the SIF recorded that Romania and Trinidad and Tobago had moved to reciprocal status and that the exchange with Uganda had been activated.⁵ The political discussion about which states should receive data has repeatedly focused on questions of data protection, corruption and the rule of law in the receiving states.

The exchanges since 2018

The first data were collected in 2017 and exchanged in the autumn of 2018. In that first round, Switzerland sent information on some two million financial accounts to thirty-six states and territories, among them the member states of the European Union with the exception of Romania and Cyprus, together with Australia, Canada, Japan, South Korea, Norway, Iceland and the Crown Dependencies. It received information on a similar number of accounts, almost half of it from Germany, followed by Portugal and Italy.⁶ The figures showed that the flows were by now two-sided. Swiss residents also held accounts abroad, and cantonal tax authorities began to use the incoming data in their assessments.

The volume grew steadily in the following years. In the exchange of 2025, the Federal Tax Administration exchanged information with 110 states, including Kenya and Thailand for the first time. The exchange was reciprocal with 84 of them. Switzerland received information from 26 states without sending data to them. It sent information on about 3.8 million financial accounts and received information on about 3.5 million, while some 9,000 reporting financial institutions were registered with the administration.⁷ These figures describe the normal state of affairs in the Swiss financial centre today. The account of a foreign resident in a Zurich bank is, in general, known to the client’s home tax authority each year.

The regime continues to evolve. The OECD adopted in 2023 a framework for the automatic exchange of information on crypto-assets, the Crypto-Asset Reporting Framework, together with amendments to the Common Reporting Standard. Switzerland has declared its intention to implement both. The Federal Assembly and the Federal Council have approved the legal basis. According to the SIF, the determination of partner states remains before Parliament, and the new rules will not apply before 1 January 2027.⁸ For Zurich, which has become an important location for crypto-asset service providers, the extension of reporting to crypto-assets closes a gap that some clients had seen as a new refuge.

Notes

1. Federal Council, Bericht zur Finanzmarktpolitik des Bundes, December 2012, https://www.newsd.admin.ch/newsd/message/attachments/35762.pdf. The report builds on the strategic directions for the financial centre adopted by the Federal Council in December 2009, with the objectives of quality, stability and integrity. ↩
2. State Secretariat for International Finance (SIF), “Legal basis and how AEOI works”, https://www.sif.admin.ch/en/legal-basis-aeoi. ↩
3. Federal Tax Administration (FTA), “Automatic exchange of information AEOI”, https://www.estv.admin.ch/en/automatic-exchange-of-information-aeoi. The page describes the flow of information from banks, collective investment schemes and insurance companies through the FTA to the foreign tax authorities. ↩
4. SIF, “Automatic exchange of information on financial accounts”, https://www.sif.admin.ch/en/automatic-exchange-information-aeoi. ↩
5. Ibid. The SIF page notes that more than 100 states and territories, including all major financial centres, have adopted the standard. ↩
6. Joel Weibel, “Informationen zu zwei Millionen Finanzkonten eingetroffen”, Die Volkswirtschaft, 24 June 2019, https://dievolkswirtschaft.ch/de/2019/06/weibel-07-2019/. ↩
7. Federal Tax Administration, “Informationsaustausch mit 110 Staaten zu rund 3,8 Millionen Finanzkonten”, press release, 10 October 2025, https://www.agov.admin.ch/de/newnsb/_gQMjMRhzI4oNy93wtgNu. ↩
8. SIF, “Framework for the automatic exchange of information (AEOI) on crypto assets”, https://www.sif.admin.ch/en/framework-for-the-automatic-exchange-of-information-aeoi-on-crypto-assets. ↩

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.