CapLaw-2026-37

On 1 July 2025, FINMA Circular 2025/4 on consolidated supervision entered into force. This codification of FINMA‘s longstanding supervisory practice for financial groups in line with international standards enhances regulatory clarity. One year after its entry into force, it makes sense to assess the Circular‘s practical impact and the extent to which consolidated supervision has featured in FINMA‘s recent practice. As this issue will likely remain relevant in the coming years, this contribution examines FINMA‘s expectations as set out in the Circular and as applied in practice.