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Switzerland

Switzerland
Our Regulatory Position

Switzerland deliberately chose not to enact an AI Act, and is not building one. Here is exactly what that means, what binds your organisation today, and how our framework covers it.

Why Switzerland sits on a different footing

Unlike the European Union, Switzerland has no comprehensive AI law, and the Federal Council confirmed on 12 February 2025 that it will not create one. Its approach is sector-specific: ratify the Council of Europe Framework Convention on AI, which applies primarily to public-sector actors, and limit cross-sectoral AI rules to fundamental-rights areas such as data protection. For a private organisation, the binding AI-relevant obligations today are data protection under the revised Federal Act on Data Protection, plus the EU AI Act wherever you serve clients in the European Union. A federal consultation bill is expected by the end of 2026.

Switzerland revFADP & Council of Europe AI Convention

Data protection anchored — no horizontal AI Act

Switzerland

Regulatory anchors: Federal Act on Data Protection (revFADP, in force 1 September 2023); Council of Europe Framework Convention on Artificial Intelligence (ratification underway); extraterritorial reach of the EU AI Act

In Switzerland, AI governance for a private organisation runs almost entirely through data protection. The revised FADP governs any AI system that processes personal data, covering automated individual decision-making, profiling, transparency and information duties, and data protection impact assessments for high-risk processing. The Council of Europe AI Convention sets the direction of travel, and organisations serving EU clients fall within the EU AI Act regardless of Swiss law. Our framework assesses this real, binding surface today, and is built to absorb the federal AI bill expected at the end of 2026 the moment it lands.

None
Horizontal AI Act
Sept 2023
revFADP in force
End 2026
Draft AI bill expected
EU AI Act
Applies extraterritorially
Sample assessment areas
Mandatory

Automated Individual Decisions

AI making decisions that produce legal or similarly significant effects on individuals. Covers the revFADP information duty, the data subject's right to be heard, and meaningful human review.

Mandatory

Profiling & Impact Assessment

High-risk processing and profiling driven by AI. Covers when a data protection impact assessment is required under the revFADP, and how risks to data subjects are documented and mitigated.

Conditional

Cross-Border Data Transfers

AI pipelines that route personal data outside Switzerland. Covers adequacy, contractual safeguards, and transparency where processing spans the EU, the Gulf, or other jurisdictions.

Full Swiss FADP & AI Governance Mapping Available on Request

Our complete Swiss category maps the revFADP obligations that bite when AI processes personal data, plus the Council of Europe Convention principles and EU AI Act exposure for Swiss organisations serving the European market.

Request Full Mapping

Operating in Switzerland? Map Your Real Exposure.

Book a 30-minute discovery call. We will identify what the revFADP and the EU AI Act actually require of your AI use, and outline the fastest path to readiness.

Book Discovery Audit