Zurich compared: language regimes of competing centres

Geneva and French

The comparison with Geneva, the subject of the companion volume, shows two different models of linguistic infrastructure within the same country. Geneva’s official language is French, and French connects the city with France, with French-speaking Africa, with the Maghreb and the Levant, and with the diplomatic world of the international organisations. The Geneva financial centre has built much of its identity on this francophone network, while its commodity trading and private banking sectors serve clients for whom French is the natural language of business and law. Article 5 of the cantonal constitution of 14 October 2012 declares French the official language and obliges the state to promote and defend it.¹ English plays a role in Geneva as prominent as in Zurich, especially in commodity trading and in the international organisations. The difference lies in the hinterland. Geneva’s French connects it with a francophone world that is large but economically diverse, while Zurich’s German connects it with the largest economy in Europe and with a dense network of family businesses, foundations and wealthy households in Germany and Austria.

Both centres also share the same federal law, so that the Geneva lawyer and the Zurich lawyer read the same statutes in their respective official languages, each version being equally binding.² The Federal Supreme Court’s case law flows between them in both languages. In practice, the two centres complement each other. Clients who need French-language advice or a connection to the francophone world go to Geneva, and clients who need German-language advice or a connection to the German-speaking world go to Zurich, while both offer English to everyone else.

Singapore and Hong Kong: English and Chinese

Singapore and Hong Kong illustrate a different model, in which English is both a language of law and a language of the state. Article 153A of Singapore’s Constitution recognises four official languages, Malay, English, Mandarin and Tamil, with Malay as the national language, while English is the main language of formal settings such as government departments and the courts.³ Because Singapore’s law derives from English common law, its legal system operates entirely in English. A foreign investor who reads a Singapore statute reads the authentic text. The Singapore International Commercial Court, established in 2015 as a division of the General Division of the High Court, sits with a panel of local and international judges and allows registered foreign lawyers to represent parties in certain circumstances.⁴ For international business, Singapore thus offers a legal infrastructure without a linguistic barrier.

Article 9 of Hong Kong’s Basic Law provides that, in addition to Chinese, English may also be used as an official language by the executive authorities, legislature and judiciary.⁵ The Official Languages Ordinance develops this principle for legislation and the courts.⁶ Hong Kong legislation is enacted in both languages with equally authentic texts, which gives Hong Kong a bilingual legal system that resembles the Swiss model more closely than any other Asian centre. Hong Kong courts may conduct proceedings in either language, applying a common law tradition inherited from the colonial period that remains in force under the principle of “one country, two systems”. The comparison shows that Zurich’s multilingual legislation is not unique. Hong Kong also operates with two authentic language versions, one of which, English, is the language of international finance. Zurich lacks this advantage because English has no official status in Swiss federal law.

Dubai: Arabic and English

The United Arab Emirates offer a third model, which separates the language of the state from the language of an enclave. Arabic is the official language of the federation under Article 7 of its Constitution, which is why the federal and emirate courts work in Arabic. The Dubai International Financial Centre and the Abu Dhabi Global Market, by contrast, are financial free zones with their own civil and commercial law, based on English common law or, in the case of the ADGM, applying English common law directly. Each has its own courts, which conduct proceedings in English.⁷ The enclave model allows the UAE to offer international business an English-language legal system without changing the language of the state. Its disadvantage is the boundary between enclave and state, which becomes visible whenever a judgment must be enforced outside the free zone or a dispute touches onshore law.

Switzerland has never followed the enclave model. The Swiss approach adds English as an option within the existing courts and authorities, as the revision of Article 129 CPC shows. The Zurich International Commercial Court, if it is established as planned, will be a chamber of the ordinary Commercial Court applying Swiss procedural law, with English as an optional language of proceedings. The difference reflects the constitutional culture of the two countries. Switzerland integrates new languages into existing institutions, while the UAE created new institutions for a new language.

Frankfurt: German and English

Frankfurt, Zurich’s closest competitor within the German-speaking area, shares Zurich’s basic situation: a German-speaking financial centre in which English has become the working language of international business. German federal law is enacted in German only, and § 184 of the Courts Constitution Act (Gerichtsverfassungsgesetz, GVG) provides that the language of the courts is German. The Federal Financial Supervisory Authority, BaFin, accepts English in many areas of its work, notably for prospectuses in the capital market.⁸ Germany has also moved towards English in court. The Act to Strengthen Germany as a Location for Justice (Justizstandort-Stärkungsgesetz), in force since 1 April 2025, allows the Länder to establish commercial courts (Commercial Courts) at the higher regional courts and commercial chambers at the regional courts in which proceedings can be conducted in English. The new courts hear disputes between businesses with a value in dispute above EUR 500,000, and English may be used where the parties agree.⁹ Hesse planned to open a Commercial Court at the Oberlandesgericht Frankfurt am Main and a Commercial Chamber at the Landgericht Frankfurt am Main by 1 July 2025.¹⁰

The parallel between the German and the Swiss reforms is remarkable. Both countries adopted legislation permitting English-language proceedings in commercial disputes, with entry into force in 2025: in Switzerland on 1 January, in Germany on 1 April. Both reforms responded to the same competitive pressure from London, Singapore, Paris and Amsterdam, which had already created English-language commercial courts or chambers.¹¹ The difference lies in the starting point. Frankfurt competes as the financial centre of the euro area and the seat of the European Central Bank, with direct access to the European single market. Zurich competes as a centre outside the European Union with a stronger tradition of private banking, a more flexible legal system and three authentic language versions of its law. For German clients, the choice between Frankfurt and Zurich is rarely a linguistic one, since both speak German and English. The linguistic infrastructure is similar. It is the legal, fiscal and political infrastructure that differs.

Notes

Constitution de la République et canton de Genève du 14 octobre 2012 (rs/GE A 2 00), Art. 5, https://silgeneve.ch/legis/data/rsg_a2_00.htm. ↩
Universität Zürich, Zentrum für Rechtsetzungslehre, slides 5, loc. cit. (Art. 14 PublG). ↩
Wikipedia, “Languages of Singapore”, https://en.wikipedia.org/wiki/Languages_of_Singapore, quoting Article 153A of the Constitution of the Republic of Singapore (“The national language shall be the Malay language …”). ↩
Singapore Judiciary, “Singapore International Commercial Court”, https://www.judiciary.gov.sg/singapore-international-commercial-court. ↩
Basic Law of the Hong Kong Special Administrative Region, Article 9, https://www.basiclaw.gov.hk/en/basiclaw/chapter1.html. ↩
“Official Languages Ordinance”, English Wikipedia, https://en.wikipedia.org/wiki/Official_Languages_Ordinance: the Official Languages Ordinance (Cap. 5) declares Chinese and English official languages with equal status, requires ordinances to be enacted and published in both languages and allows judicial officers to use either language in court proceedings. ↩
DIFC Courts, “DIFC Courts”, https://www.difccourts.ae/about/difc-courts, describing the courts, established by Dubai Law No. 12 of 2004 as amended by Dubai Law No. 16 of 2011, as “a unique common law, English language jurisdiction” for civil and commercial disputes, open also to parties without a connection to the DIFC who agree in writing to their jurisdiction. ↩
§ 21 of the Wertpapierprospektgesetz (WpPG), https://lxgesetze.de/wppg/21, recognises German and English as languages for prospectuses under Regulation (EU) 2017/1129, and English alone for certain cases. § 184 sentence 1 GVG: “Die Gerichtssprache ist deutsch”, https://lxgesetze.de/gvg/184. ↩
Gleiss Lutz, “Justizstandort-Stärkungsgesetz – Einführung von Commercial Courts und Englisch als Gerichtssprache”, https://www.gleisslutz.com/de/know-how/justizstandort-staerkungsgesetz-einfuehrung-von-commercial-courts-und-englisch-als-gerichtssprache, on § 184a GVG and the threshold of EUR 500,000. ↩
UEPO.de, “Gerichtssprache Englisch: OLG Frankfurt richtet Commercial Court und Commercial Chamber ein”, 12 February 2025, https://uepo.de/2025/02/12/gerichtssprache-englisch-olg-frankfurt-richtet-commercial-court-und-commercial-chamber-ein/, also stating that the Justizstandort-Stärkungsgesetz takes effect on 1 April 2025. ↩
Cour d’appel de Paris, “La chambre commerciale internationale de la cour d’appel de Paris”, https://www.cours-appel.justice.fr/paris/la-chambre-commerciale-internationale-de-la-cour-dappel-de-paris, referring to “la création de la CCIP-CA en 2018”. De Rechtspraak, “Netherlands Commercial Court”, https://www.rechtspraak.nl/English/NCC/Pages/default.aspx: “The Netherlands Commercial Court was created on 1 January 2019.” ↩

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.

English

Contact

Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

Get in touch →