Cloud Computing

The use of cloud technology is a critical success factor for Switzerland and its financial centre. A clear understanding of the legal and regulatory requirements and risks is essential in order to be able to use this technology safely in the financial sector.  

Cloud technology as the basic infrastructure for digital transformation 

Migrating infrastructure and processes to a cloud can reduce the time it takes for banks to bring innovative products and services to the market and thus increase their competitiveness. The cloud enables banks to exploit new technologies such as artificial intelligence without making substantial investments in their own hardware and software. Access to a large pool of data and the corresponding computing power allows large data volumes to be analysed in real time. The cloud also permits substantial efficiency gains in the development and testing of new applications and systems. 

What is a cloud? 

Cloud computing is a model for enabling ubiquitous, convenient, on-demand network access to a shared pool of configurable computing resources (e.g. networks, servers, storage, applications and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction. There are three types of cloud service: Infrastructure as a Service (IaaS), Platform as a Service (PaaS) and Software as a Service (SaaS). These can be provided via a private, community, public or hybrid cloud.

Source: definition according to NIST
(https://csrc.nist.gov/publications/detail/sp/800-145/final) 

Overcoming legal and regulatory challenges in a business-friendly manner

Cloud services come along with specific challenges and risks. In particular, banks must comply with professional secrecy requirements under the Banking Act, comply with data protection law, guarantee data security and resilience, and actively manage dependencies on individual cloud providers in order to avoid any loss of control. Against this backdrop, banks need to adapt their cloud strategy and architecture continually to changing external conditions as well as their own needs.  

Position of the Swiss Bankers Association

Given the great potential of cloud technologies for the digital transformation of the banking industry, the Swiss Bankers Association (SBA) is committed to ensuring optimal framework conditions.  

The SBA's cloud guidelines show banks practical solutions for implementing and operationalising the applicable legal and regulatory requirements by means of appropriate technical and organisational measures. Each bank must define its own strategy as to whether, how and which data should be migrated to the cloud. 

Links & Documents

Cloud Guidelines (2025).pdf

PDF04.11.2025

Appendix to the Cloud Guidelines (2025).pdf

PDF04.11.2025

Legal opinion: Permissibility of disclosure by Swiss banks of bank client information to agents in foreign countries under Article 47 of the Banking Act (Walder Wyss AG) (2019)

PDF24.04.2019

Legal opinion:Use of Cloud Offerings by Banks: Admissibility under Art. 47 Banking Act: (Laux Lawyers AG) (2019)

PDF24.04.2019

Experts

Richard Hess
Head of Digital Finance
+41 58 330 62 51
Natalie Graf
Senior Legal Counsel
+41 58 330 62 42
News14.12.2020

Certification system for cloud services to be evaluated

On 11 December, the Federal Council took note of the needs assessment conducted for a “Swiss cloud”. The corresponding report includes findings from preliminary work done by the Swiss Bankers Association (SBA) and identifies the need for a “Swiss cloud” that meets specific requirements relating to data sovereignty. As part of planned additional measures, the Federal Council has commissioned an evaluation and specification of a certification system for cloud services.
News14.11.2019

Banking goes to the cloud

Together with legal experts and specialists from industry and the authorities, over 150 participants discussed the opportunities and regulatory issues surrounding cloud technology for banks at the Swiss Bankers Association’s event.
Press releases26.03.2019

Secure cloud banking: SBA guidelines pave way towards future

Basel, March 26, 2019 – Swiss banks are very interested in the subject of cloud computing, but they have so far been reluctant to migrate their data to the cloud. This is because certain questions regarding the legal and regulatory frameworks remain unanswered. The SBA has therefore worked with member institutions, audit firms and cloud providers to draw up a set of guidelines containing recommendations intended to make it easier to move to the cloud. The guidelines, together with a video explaining cloud banking, are being published on 26 March 2019.
News26.03.2019

Guide to secure cloud banking

The Swiss Bankers Association (SBA) has worked with member institutions, audit firms and providers to draw up a set of guidelines for the use of cloud services. The guidelines contain recommendations intended to help banks migrate their data to the cloud more easily and securely.