Personal Responsibility in Swiss Banking: What It Could Mean for Senior Management
Capital requirements have dominated the discussion about Swiss banking this year. But another regulatory proposal may have a more direct impact on how banks are actually managed. The idea is relatively simple: at larger banks, it should become clearer which senior executive is personally responsible for which decisions and areas of the business. At the largest institutions, variable compensation could also remain at risk for longer and potentially be reclaimed if serious problems emerge later.
At first sight, this may sound like another governance topic. I believe it is more fundamental. Capital requirements primarily affect balance sheets, while a stronger individual responsibility framework affects management itself. It raises a simple question: who is actually responsible when something goes wrong?
From Collective to Individual Responsibility
Swiss corporate governance has traditionally placed considerable emphasis on collective decision making. Boards decide collectively, executive committees decide collectively, and important decisions often involve several functions and committees. There are good reasons for this. Banking is complex, and major decisions should benefit from different perspectives.
But there is also an obvious weakness. If responsibility is shared among many people, it can become difficult afterwards to establish who was actually responsible for a particular decision. The collapse of Credit Suisse in 2023 illustrated this rather clearly. There was no shortage of governance structures and senior executives, yet individual responsibility remained difficult to establish.
The current proposal could therefore change more than documentation. It could change how responsibility itself is understood within Swiss banks.
A New Generation Is Running Swiss Banking
The timing is interesting because senior leadership across Swiss banking has changed substantially in recent years. Together with Claude Baumann, I recently examined this development in our study The 100 Most Influential Bankers in Switzerland 2026, published by WealthSummit, a private research company not affiliated with ZHAW.
More than half of the 100 personalities covered have held their current position only since 2022. Thirty six took up their role in 2024 or later, while only sixteen have been in the same position since 2015 or earlier. A significant part of Swiss banking leadership is therefore relatively new in role.
The backgrounds are also becoming more diverse. Traditional banking careers remain important, but experience in consulting, investment banking, technology and transformation is increasingly common. This creates an interesting situation because many executives who may in future carry explicitly documented personal responsibility did not design the organizations and governance structures for which they will be responsible.
Lessons from the UK
Switzerland is not the first financial center to move in this direction. The United Kingdom introduced a comparable approach around ten years ago. One benefit was greater transparency. Banks had to define much more clearly who was responsible for what, and in doing so sometimes discovered gaps and overlaps in their own structures.
But personal accountability can also change behavior. If an executive knows that an important decision may later be attributed personally to him or her, the natural response may be to document more, escalate more and involve more people. This can improve governance, but it can also make a bank slower.
There may also be implications for recruitment. A senior position looks different if it combines substantial personal responsibility with deferred compensation and possible future clawbacks. This is not an argument against greater personal responsibility, but it is an argument for implementing it carefully.
What Should Senior Management Be Asking?
For boards and executive teams, the most relevant questions are practical:
- Who actually decides?
- If a serious problem emerged tomorrow, would it be obvious which executive was responsible?
- Where responsibility is shared between a global function and a Swiss entity, who ultimately owns the decision?
- Does the person named as responsible actually have the authority required to carry that responsibility?
This last point matters. There is a risk that banks respond by producing increasingly elaborate governance documents designed mainly to protect individuals. The result could be a structure that looks convincing on paper but does not reflect how decisions are really made. That would achieve very little.
Mid sized institutions may face a particular challenge. The largest Swiss banks already have substantial governance and compliance infrastructures, while a bank with a few hundred employees and a small management team often relies more heavily on informal coordination. For these institutions, defining individual responsibility may require more than another policy document.
Leadership Is Becoming More Important
There is also a broader point. Banking has become more regulated, more technological and more complex. It would therefore be easy to assume that individual personalities matter less. I believe the opposite may be true.
The more complex an organization becomes, the more important it is to understand who has authority, who makes decisions and who is prepared to take responsibility for them. Looking at the current generation of Swiss banking leaders also shows how quickly the leadership landscape is changing. New CEOs, chairmen and management teams are taking responsibility at a time when regulatory expectations are increasing.
For researchers and students, this creates an interesting case. Does clearer personal responsibility improve decisions? Does it mainly improve documentation? Does it change management behavior? And does it influence who is willing to take on a senior leadership role?
These are not merely regulatory questions. They go to the heart of corporate governance. Modern organizations want decisions to benefit from collective expertise, while regulators, shareholders and the public increasingly expect somebody to be personally accountable for the outcome. Finding the right balance between the two may become an important governance challenge for Swiss banking.