A member of FINMA’s Executive Board since 2014 and head of the new Asset Management & Markets division since April 2025, Léonard Bôle shares his insights on the supervision of asset managers.
Since 2020, asset managers have been required to obtain authorisation from FINMA. What are your observations regarding developments within this sector?
As part of our authorisation activities, we have observed continued dynamism in this sector. The consolidation that was predicted – and feared by some – has not yet materialised. Here are a few figures to illustrate my point. FINMA received 1,534 licence applications from asset managers who were already active when the new laws, the Financial Services Act (LEFin) and the Financial Services Providers Act (LSFin), came into force. Since then, we have received over 210 further applications from new entities, of which more than 160 have already been authorised. To date, FINMA has authorised a total of more than 1,520 asset managers (statistics as at 30 June 2026).
What conclusions can be drawn from these figures?
Admittedly, a number of institutions did not meet the necessary standards and could not be authorised. Others have ceased their asset management activities after receiving authorisation. However, these figures demonstrate that the new regulations have been applied proportionately by FINMA and in no way hinder the innovation and entrepreneurial spirit of small institutions, which are characteristic of this sector.
How does the supervisory system for asset managers work?
The system, chosen by the legislator following close consultation with industry representatives, is somewhat complex. FINMA is responsible for authorising institutions, as well as any subsequent significant changes. It must also authorise and supervise the supervisory bodies (SBs), of which there are currently four, down from five previously. These supervisory bodies are responsible for the day-to-day supervision of the institutions. In practice, they rely on the audit firms appointed by the institutions to carry out this work. The supervisory bodies must also approve and supervise these audit firms.
And at what point does FINMA intervene in the supervision of asset managers?
When the supervisory bodies identify serious breaches or persistent violations, they report these to FINMA, which must then intervene through intensive supervision or even enforcement proceedings. Overall, this is therefore a complex system, which distributes supervisory tasks across several levels and requires a great deal of coordination. FINMA has implemented it as effectively as possible. For example, it has developed its digital data-sharing platform to enable simultaneous communication between institutions, supervisory bodies and FINMA.
FINMA recently published a supervisory notice (03/2026) on risks in the asset management sector. Why?
As part of our intensive supervision, we have observed an increase in reports of serious breaches involving a similar risk pattern. These were often cases in which the offending institution used its own products – for example, foreign funds without equivalent supervision or ‘actively managed certificates’ – with complex, multi-layered structures linked to risky, illiquid or even undiversified investments. The combination of these factors substantially increases the risks for clients. These cases are particularly serious when the manager fails to provide transparency regarding risks or conflicts of interest, or even fails to verify the suitability of investments, particularly for private clients with limited risk tolerance.
How many cases are we talking about here, and what are the consequences?
These cases concern a small minority of the population and cannot under any circumstances be generalised. However, even a few cases can be enough to damage the reputation of an entire sector. In the most serious cases, the assets entrusted by clients amount to tens, or even hundreds, of millions. The supervisory authority’s action and its firm stance on this type of breach are important for client protection, which lies at the heart of FINMA’s legal mandate and concerns. They also help to establish the prudential supervisory system and, in so doing, strengthen the sector’s reputation.
What are the challenges in supervising asset managers?
In addition to the serious and complex cases handled by FINMA, day-to-day supervision by the supervisory bodies is fundamental to the early identification of problems. We have already mentioned the risks to investors and the importance of monitoring conduct of business rules. However, the challenges are manifold. For example, asset managers are exposed to various operational risks relating to IT and cyber-attacks. Furthermore, they often delegate risk management to external service providers, which can sometimes lead to unclear lines of responsibility and gaps in controls.
Has the implementation of the supervisory system now been completed?
FINMA has worked extensively with the OSs in recent years to put the supervisory system in place. The progress made is undeniable. However, during its on-site inspections of the OSs, FINMA identified areas for improvement, such as significant delays in processing audit reports. It has also asked the OSs to be more diligent in their assessment of audit firms’ competence. It is closely monitoring progress in this area. It is doing the same with regard to the work resulting from the recent merger of two audit firms. Finally, it is worth noting that a supervisory system can never really be regarded as a finished product. It must be constantly improved and adapted to evolving risks.
Has the sector adapted well to this prudential supervision?
The introduction of prudential supervision represents a significant change. In particular, compared with the previous system of self-regulatory bodies – which was limited to combating money laundering – the new regulations cover areas as essential and varied as investor protection, good governance, risk management and financial stability. The impact of such a reform, including the costs involved, continues to raise questions and provoke critical reactions even today. This is due to the scope of the reform, but also undoubtedly to the complexity of the system. This is why we have organised various discussions and round-table meetings with representatives of industry associations.
What is your assessment of this reform?
The LSFin and LEFin reforms were an important and necessary step towards investor protection. The introduction of prudential supervision serves to strengthen the sector’s reputation, which is essential for building client trust. It also brings further benefits in terms of market access. For example, agreements have recently been reached with the US and UK authorities, opening up opportunities for asset managers to offer cross-border services. On the other hand, this supervisory system involves a certain degree of complexity. At international level, it is unique and requires a significant effort to explain it to our counterparts or in the context of international assessments. Finally, it should be noted that any reassessment of a supervisory system is a matter for the legislature. In the meantime, FINMA will continue its efforts to protect investors and implement the current system as effectively as possible.