BaFin Exemption

This webpage collects documents and further information related to this topic that are to be shared and have already been shared.

Update June 2020

  • 18.6.2020: SBA draft audit programme (subject to comments and finalisation): DOC
  • 18.6.2020: SBA draft self-certification (subject to comments and finalisation): DOC

Update May 2020

  • AFBS Memo TelCo update 5.5.2020: DOC

Update Spring 2020

Exchange of Letters SBA-FINMA/SIF

  • 3.3.2020: summary SIF SBA discussions: DOC
  • 4.2.2020: SBA outline of concerns: DOC
  • 4.2.2020: SBA letter to the SIF: DOC
  • 4.2.2020: SBA letter to the FINMA: DOC

Update 23.12.2019

The call among Swiss banks concluded the following points:

  • withdrawal of non-exemption for areas not relevant for private wealth management (e.g. algo-trading)
  • banks individually file their comments on the BaFin letter before Christmas; no further need for coordination was identified
  • the SBA shall not be involved for a comparative assessment of the legal framework
  • next steps for a coordinated involvement of the FINMA shall be undertaken early in January


Comparison of Legal Bases

General Information

AFBS Memo: BaFin Exemption