Deloitte FIDLEG Center-of-Excellence

Deloitte has established a FIDLEG Center-of-Excellence comprised up of experienced regulatory experts, many of them with a significant PRIIPs and MiFID II background. The objective is to make sure that our clients go well supported and ready into the expected enforcement of FIDLEG in 2020. On this page, we will share our expertise and provide insights on the regulation from various angles, adding value by broadening the perspective on the regulation.

FIDLEG timeline

FIDLEG rather a chance than another regulatory burden

In November 2015, the Federal Council adopted the dispatch on the Financial Services Act (FIDLEG) and the Financial Institutions Act (FINIG). With FIDLEG, the Swiss Federal Council and Parliament seek to strengthen the protection of investors by improving transparency and reducing the information asymmetry between financial services institutions and clients. It is also an answer to the EU’s evolving regulation of financial markets, as FIDLEG aims to harmonise rules to create a level playing field for activities comparable to those governed by the MiFID II legislative framework. At its core, FIDLEG sets out a code of conduct, which substantially expands the rules for investment advice and information disclosure.

On 15 June 2018, the Swiss Council of States and the Swiss Federal Council have adopted FIDLEG & FINIG in the final vote of the summer session. At the current moment in time, FIDLEG can be anticipated to enter into force in early 2020. The ordinances and several other official interpretations such as implementation guidelines, helping to clarify and detail the requirements, are expected to be published in autumn 2018.

Deloitte has built profound knowledge and experience in implementing regulations with its clients amongst these MiFID II and PRIIPs as European FIDLEG counterparts. In order to continue our client journeys and successfully implement the FIDLEG requirements, Deloitte has built a FIDLEG Centre-of-Excellence. The aim of our services is to support Deloitte clients starting with the initial gap-assessment to the implementation and later reassurance of the requirements.

Alongside, we will also publish FIDLEG specific blogs, sharing our experiences, knowledge and insights on

  • Implementation challenges,
  • technology developments facilitating regulatory compliance and 
  • synergies/ quick wins clients can reach while implementing FIDLEG.

Deloitte is aware that the degree of impact on each organisation implementing FIDLEG will depend on the set-up, pre-work done in the course of other regulations and other ongoing initiatives. Our experts are happy to provide tailored insights in a dedicated meeting at your request.

FIDLEG Insights

22.10.2019 - FIDLEG – A sneak peek at potential ordinance changes and implications

Summer vacations are over and temperatures outside are slowly falling to autumn levels. In contrast, the heat is steadily rising for banks, with the Financial Services Act (FinSA/ German: FIDLEG) expected to come into force on 1 January 2020. The Federal Department of Finance (FDF) will ask the Federal Council to bring FIDLEG and the Financial Institutions Act (FinIA/ German: FINIG) - together with the Federal Council's implementing ordinances - into force on that date. A transition period of two years is anticipated (source: SIF). However, some voices are calling for an initial transition period of one year only, which will force banks to return to their initial project timeline.

Read more on our banking blog

04.03.2019 - FIDLEG and FINIG – What Asset Managers need to know and do

With both FIDLEG and FINIG expected to come into force on 1 January 2020, the ancestral business of Fund Managers and Asset Managers in Switzerland will face minor material changes, while the impact of FINIG is predicted to be more significant especially for Independent Asset Managers (IAMs). A substantial reorganisation will be required in order to meet the new licensing requirements. Despite the potential benefits afforded by a long transitional period, existing IAMs are advised to consider their transformation efforts early.

This blog post in our FIDLEG series illustrates the fields of action for collective Asset Managers and sheds light on new challenges and solutions for their Independent peers.

Read more on our banking blog

29.11.2018 - FIDLEG – How the market participants see it

In light of the published draft ordinance, Deloitte hosted the webinar “FIDLEG: Seeing beneath the surface ”. The objective of the webinar was to address the provisions refined by the ordinance and outline their operational impact on financial organisations, while highlighting key commonalities and differences to European legislation. Alongside the webinar, the participants provided valuable insights regarding the FIDLEG implementation within their organisations. The fifth blog post in our FIDLEG series considers the outcome of these poll questions and addresses the implications for a successful regulatory journey.

Read more on our banking blog

11.10.2018 - FIDLEG – How did we get so late so soon?

With FIDLEG expected to come into force on 1 January 2020, financial services providers in Switzerland will need to comply with a new set of investor protection requirements.

This fourth blog post in our FIDLEG series considers an illustrative roadmap for effective FIDLEG implementation. It outlines why financial institutions should start addressing FIDLEG now to ensure a smooth journey to compliance.

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04.10.2018 - Webinar: FIDLEG - Seeing beneath the surface

FIDLEG (engl. FinSA) sets out cross-sector rules for offering financial services and distributing financial instruments. The rules are aligned with the EU directives (MiFID II, Prospectus Directive, PRIIPs). However, FIDLEG includes important adjustments made to reflect the specific Swiss circumstances. Institutions that did not implement MiFID II will have to battle with new requirements facing their clients based in and served our of Switzerland. For all the others, there are good opportunities to leverage work already done or take advantage of some of the differences. However, it all takes time.

Read more on our banking blog

20.08.2018 - FIDLEG – 8 key design decisions financial institutions should consider

With the adoption of FIDLEG, Swiss financial institutions will need to amend their advisory processes to comply with these new rule sets. This third blog post of our FIDLEG series explores 8 key design decisions financial institutions should consider when implementing FIDLEG. In particular, it showcases the impact of the new rules on the onboarding as well as offering and sales stages of the advisory value chain. By taking relevant design decisions early, financial services providers can significantly reduce the burden and increase the speed of implementation. Early pro-activeness to prevent cumbersome reactions.

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23.07.2018 - FIDLEG – Beyond MiFID II experiences

Our previous blog on the FIDLEG topic dealt with the genuine connection between Swiss FIDLEG and its EU counterparts (MiFID II or PRIIPs), offering potential synergies in the implementation due to similarities in their objective and scope.

We now focus more specifically on FIDLEG requirements linked to (client) advisory going beyond respective MiFID II requirements or not existing under MiFID II. Ultimately, these insights also set the stage for financial services providers having to define the scope and approach of their implementation of the FIDLEG requirements.

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25.06.2018 - FIDLEG – Knowing how to leverage MiFID II implementations

With players in the financial services industry already having undertaken a major effort to implement MiFID II and PRIIPs, they may now face similar challenges with FIDLEG. This first blog post in our FIDLEG series draws parallels with the most challenging requirements already experienced during the MiFID II implementation journey.

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