# How does the FINMA regulate AI in banking?

Source: https://www.bankingnewsai.com/ai-regulation/finma
Last updated: Oct 5, 2026

Switzerland has no AI-specific legislation, so FINMA regulates AI in banks through its technology-neutral governance and risk-management requirements. Its Guidance 08/2024, published on 18 December 2024, sets out what FINMA observed in supervision across seven areas: governance, inventory and risk classification, data quality, tests and ongoing monitoring, documentation, explainability and independent review. A FINMA survey published on 24 April 2025 found that around 50% of the roughly 400 institutions surveyed use AI or have initial applications in development. FINMA says it will refine its expectations and make them transparent in the market where necessary.

## At a glance

| Field | Value |
| --- | --- |
| Full name | Swiss Financial Market Supervisory Authority (FINMA) |
| Jurisdiction | Switzerland (banks, securities firms, insurers, fund managers, managers of collective assets, financial market infrastructures and other supervised institutions) |
| Role | Integrated Swiss financial supervisor that sets AI expectations through supervisory guidance rather than AI-specific law |
| How binding | Supervisory guidance |
| Applies to | Institutions supervised by FINMA — including licensed banks and securities firms — that develop or use AI; FINMA's 2025 survey covered about 400 banks and securities firms, insurers, insurance intermediaries, fund management companies, managers of collective assets and financial market infrastructures |
| Key document | FINMA Guidance 08/2024: Governance and risk management when using artificial intelligence (18 December 2024) |
| Latest move | 24 April 2025: FINMA published a survey of around 400 Swiss financial institutions showing about half use AI or have initial applications in development, following its Guidance 08/2024 of 18 December 2024 |

## Overview

FINMA's position is stated in Guidance 08/2024: in financial market law, the technology-neutral, principle-based requirements for effective governance and risk management already cover the risks arising from AI, and FINMA expects supervised institutions to align governance, risk management and control systems with the impact of AI on their risk profile, taking into account the materiality of applications and the probability that risks materialise. The guidance is a statement of supervisory observations and assessments rather than a rule, and it notes that AI is not a high-risk application per se: the risk depends on complexity, adaptivity and autonomy, area of application and integration into processes.

The survey published on 24 April 2025 gives the empirical background: 91% of respondents that use AI also use generative AI, most institutions rely at least partly on external providers, and FINMA draws attention to outsourcing risks. On AI governance, around half of institutions have an explicit AI strategy, and data quality, data protection and explainability are the highest-priority risks. FINMA's earlier dossier page states that it has conducted on-site inspections and supervisory exchanges with institutions deploying AI extensively since the fourth quarter of 2023.

## Documents (1)

- Dec 18, 2024 — [FINMA Guidance 08/2024](https://www.bankingnewsai.com/ai-regulation/documents/finma-guidance-08-2024): FINMA Guidance 08/2024: Governance and risk management when using artificial intelligence (Final)

## Timeline

- Apr 24, 2025 — [FINMA publishes survey on AI use at Swiss financial institutions](https://www.finma.ch/en/news/2025/04/20250424-mm-umfrage-ki/) — Survey of around 400 licensed banks and securities firms, insurers, insurance intermediaries, fund management companies, managers of collective assets and financial market infrastructures, run between the end of November 2024 and mid-January 2025. About 50% use AI or have initial applications in development and a further 25% intend to within three years; 91% of AI users also use generative AI; around 50% have an explicit AI strategy.
- Dec 18, 2024 — [FINMA Guidance 08/2024](https://www.bankingnewsai.com/ai-regulation/documents/finma-guidance-08-2024): FINMA Guidance 08/2024 — FINMA Guidance 08/2024: Governance and risk management when using artificial intelligence — FINMA Guidance 08/2024, published on 18 December 2024, describes FINMA's observations from ongoing supervision on governance and risk management when supervised institutions use artificial intelligence.

## What to watch next

- FINMA's stated intention in Guidance 08/2024 to refine its expectations of AI governance and risk management and make them transparent in the market where necessary
- Continued on-site inspections and supervisory exchanges on AI governance, inventories, testing and independent review at institutions with many or material AI applications
- Whether FINMA's technology-neutral approach is adjusted to international developments such as the FSB's work on AI monitoring, which Guidance 08/2024 cites as a reference point

## FAQ

### Does Switzerland have an AI law that applies to banks?

No. FINMA Guidance 08/2024 states that to date there is no AI-specific legislation in Switzerland and that technology-neutral, principle-based financial market law on governance and risk management covers AI risks.

### Is FINMA Guidance 08/2024 binding?

It is guidance, not a rule. It describes FINMA's observations from ongoing supervision and the measures it assessed, and signals what FINMA expects supervised institutions to consider; the underlying governance, risk-management and operational-risk requirements are binding.

### What does FINMA expect banks to do about AI risk?

Maintain central AI governance with a complete inventory and risk classification, define responsibilities, ensure data quality, test and monitor applications (including data drift), document material applications, ensure explainability where decisions must be justified, and have material applications independently reviewed.

Related authorities: [BaFin](https://www.bankingnewsai.com/ai-regulation/bafin), [DNB / AFM](https://www.bankingnewsai.com/ai-regulation/dnb), [ACPR](https://www.bankingnewsai.com/ai-regulation/acpr), [FSB](https://www.bankingnewsai.com/ai-regulation/fsb), [Basel Committee](https://www.bankingnewsai.com/ai-regulation/basel-committee), [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk).

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