US FATCA requests target 49 Swiss banks and financial institutions

Brussels, 22 October 2026

Switzerland’s Federal Tax Administration has published 33 new US FATCA group request notices and 16 final decisions involving Swiss banks and insurers. The proceedings concern the possible disclosure of US-linked account data to the Internal Revenue Service, subject to Swiss administrative and judicial safeguards.

Explanatory summary

The Swiss Federal Tax Administration (FTA) published two sets of notifications on 16 October 2026 under the Foreign Account Tax Compliance Act (FATCA), covering 49 listed financial institutions: 33 notices of received group requests and 16 notifications of final decisions. These represent two different stages of the administrative assistance procedure, rather than two separate types of US requests.

1. Group requests received under Article 12(1) of the Swiss FATCA Act

The first category concerns 33 banks, insurers and other financial institutions, including J.P. Morgan (Suisse), Citibank (Switzerland), BNP Paribas, LGT Bank, Migros Bank and several cantonal banks.

Under the FATCA agreement, Swiss financial institutions report certain US-linked accounts directly to the US Internal Revenue Service (IRS) when account holders consent. Where consent is withheld, relevant account information has historically been reported in aggregated form. The IRS may subsequently request identifying information about the accounts covered by these aggregated reports.

The Swiss FTA examines these group requests and requires the institutions concerned to provide the relevant documentation within ten days. Affected persons have 20 days from publication to comment on the proposed transmission of their information and may challenge whether the conditions for disclosure are met.

The information potentially transmitted includes account-holder identification, account numbers, balances and income such as interest and dividends. The notifications do not establish tax evasion or other wrongdoing by the institutions or their customers.

2. Final decisions under Article 5(3)(b) of the FATCA Agreement

The second category covers 16 financial institutions, including Bank Julius Bär, HSBC Private Bank (Suisse), EFG Bank, Zürcher Kantonalbank, Swiss Life and Basler Kantonalbank.

These notifications concern a later procedural stage: the FTA has issued final administrative decisions on whether information relating to affected account relationships may be transmitted to the IRS.

Affected persons can appeal against these decisions before the Swiss Federal Administrative Court within 30 days of notification or publication. If no appeal is lodged, or the FTA’s decision is upheld, the requested information can be transferred to the IRS.

Importantly, the publication of a final decision does not necessarily mean that the data have already been transmitted. Nor does it indicate that any individual financial institution has violated FATCA requirements.

3. Significance for US-Swiss financial cooperation

The notifications illustrate the continuing implementation of the existing US-Swiss FATCA framework. Switzerland currently operates a Model 2 arrangement involving direct reporting by financial institutions and administrative assistance for certain accounts that could not be disclosed directly.

The two governments signed a new Model 1 FATCA agreement in June 2024, intended to introduce reciprocal automatic exchanges between tax authorities, with implementation planned for 2029 at the earliest.

The October notifications therefore concern the established group-request mechanism rather than a new US enforcement regime. The FTA has not disclosed the number of individual accounts affected, their combined value or whether the 16 final-decision proceedings originated from requests published in earlier notification rounds.

E-summary by ChatGPT, prompted by Insight EU, based on the publication below.

Administrative assistance in accordance with FATCA: notification of receipt of FATCA group requests pursuant to Article 12 paragraph 1 FATCA Act and publication of final decrees pursuant to Article 5 paragraph 3 letter b of the FATCA Agreement

Bern, 16 October 2026

The Federal Tax Administration has published FATCA group requests pursuant to Article 12 paragraph 1 FATCA Act and final decrees pursuant to Article 5 paragraph 3 letter b of the FATCA Agreement.

Source – Swiss Government

FATCA Notifications of 16 October 2026

Administrative assistance in accordance with FATCA: notification of receipt of FATCA group requests pursuant to Article 12 paragraph 1 FATCA Act and publication of final decrees pursuant to Article 5 paragraph 3 letter b of the FATCA Agreement

Administrative assistance in accordance with FATCA: notification of receipt of FATCA group requests pursuant to Article 12 paragraph 1 FATCA Act

Administrative assistance in accordance with FATCA: publication of final decrees pursuant to Article 5 paragraph 3 letter b of the FATCA Agreement

Source – Swiss Government