Why an activist investor says Switzerland’s tougher rules could push the country’s last universal bank to move — and what it would mean for finance, politics and UBS’s strategy.

Cevian Capital has escalated pressure on UBS, warning that Switzerland’s newly proposed capital regime risks forcing the country’s largest lender to move its headquarters out of Zurich. Lars Förberg, the activist fund’s co‑founder, told the Financial Times that under the current blueprint it is “not viable” to run a big international bank from Switzerland. Cevian, which holds about 1.4% of UBS, argues the measures would leave the group with “no other realistic option but to leave” to protect its competitiveness.

The confrontation adds fresh urgency to a policy fight that has simmered since the government unveiled its post‑Credit Suisse overhaul in June. Bern’s plan would tighten the “too big to fail” framework with higher loss‑absorbing capital for systemically important banks with extensive foreign subsidiaries, tougher liquidity standards, and stronger powers for the regulator Finma. UBS, which absorbed Credit Suisse in 2023, says the package departs from global norms and would penalize it versus U.S. and EU rivals.

What’s on the table
Officials have not set a final number, but the working parameters suggest UBS could ultimately face as much as $26 billion in additional capital needs, according to people familiar with the process and recent government briefings. Some elements—such as excluding software and deferred tax assets from core capital—could raise requirements by roughly high single‑digit billions alone, while the broader recalibration for cross‑border groups accounts for the rest. The Federal Council has signaled that parts of the package will proceed via ordinance, while the full legislative revamp will run through Parliament, potentially stretching implementation into the latter part of the decade.

In a sign of momentum, both chambers this month cleared the way for the government to enact certain capital‑quality changes directly, rejecting attempts to fold every plank into a single parliamentary vote. That decision narrows UBS’s margin for maneuver and strengthens the hand of officials who argue that the state must be better protected after taxpayers were left exposed during Credit Suisse’s chaotic rescue.

UBS has pushed back hard. Executives argue the proposals overshoot Basel standards, risk fragmenting global rules, and would make it costlier to support clients in growth markets while producing little marginal safety benefit at the group level. “We strongly disagree with the extreme increase in capital requirements,” the bank said in June when the parameters were first laid out. Chief executive Sergio Ermotti has maintained that it is “too early” to pre‑judge outcomes but has not ruled out options if the final shape of the rules is too punitive.

Why Cevian is raising the stakes
Cevian’s intervention is notable both for its bluntness and for the constituency it represents: shareholders frustrated that Switzerland is, in their view, shifting systemic risk costs disproportionately onto UBS’s investors. Förberg’s argument is straightforward: if Swiss policymakers are telling the market that UBS is “too big for Switzerland,” then the logical response is to headquarter the bank in a jurisdiction where the capital framework matches the scale of its operations and where the parent no longer bears extra Swiss‑specific buffers.

The fund also contends that lobbying is unlikely to soften the stance in Bern, pointing to lawmakers’ recent votes and an official post‑mortem that found Switzerland’s existing regime fell short. That posture, coupled with a still‑elevated political sensitivity around banking rescues, underpins Cevian’s conclusion that relocating the holding company—likely to the United States or an EU member state—is now a realistic scenario rather than mere negotiating theater.

Could UBS really move?
Relocating a global bank’s headquarters is no trivial exercise, but it is not unprecedented. A move would require sign‑offs from multiple regulators, careful treatment of capital and liquidity stacks across subsidiaries, and decisions about the location of group risk, finance and compliance functions. Tax, legal entity, and human‑capital considerations loom large too: Zurich remains a magnet for wealth‑management talent, and the Swiss brand is entwined with UBS’s identity.

Still, the bank’s center of gravity has shifted. UBS generates most of its profits from global wealth management and U.S. asset management, while its investment bank is calibrated for advisory and markets activity across the Atlantic and in Asia. If the incremental Swiss buffers materially raise group funding costs or constrain payouts, the board may conclude that an overseas parent domicile—paired with a large Swiss hub—better aligns regulation with risk.

For Switzerland, the optics would be stark. After the demise of Credit Suisse, the country would watch its last universal bank move its legal seat abroad, even if major operations and thousands of jobs stayed on the Limmat. Supporters of the reform counter that the aim is not to push UBS out, but to ensure that if stress re‑emerges, losses fall on investors and foreign subsidiaries, not the Swiss state.

Politics, process and the timeline
From here, three clocks are running. First, the government can implement targeted “capital quality” measures by ordinance in the near term. Second, a broader legislative package—covering enhanced liquidity, recovery and resolution, and governance tools—will go through consultation and parliamentary debate, likely into 2026–27. Third, UBS’s own strategic review must assess at what point uncertainty becomes a drag on competitiveness and valuation.

Parliamentary dynamics remain fluid. Some lawmakers warn that overshooting could backfire if it drives the group to re‑domicile. Others argue that Switzerland, now home to a single universal bank, cannot risk another weekend rescue and should err on the side of resilience. Finma has publicly welcomed the thrust of the reform, saying it will strengthen crisis preparedness.

Markets are listening
UBS shares have rallied strongly in 2025 as investors digested cost‑cutting progress and revenue momentum, even with the regulatory cloud. Yet analysts caution that the stock’s long‑term relative performance versus U.S. peers could suffer if Switzerland imposes capital that is meaningfully above international comparators. On the other hand, the perceived probability of a headquarters move—should it neutralize the capital overhang—has become part of the bull case for some investors.

Debt markets are another barometer. Additional requirements would raise the bank’s total loss‑absorbing capacity targets and could change the mix of senior and subordinated funding. If the parent company moves, the distribution of issuance across jurisdictions would shift accordingly, with potential implications for Swiss franc markets.

What relocation would mean in practice
If UBS re‑domiciled to the U.S., the holding company would likely fall under Federal Reserve oversight with capital calibrated to U.S. rules, including stress testing and long‑term debt requirements that are currently being finalized. An EU option—perhaps a eurozone financial center—would plug the group into the Single Supervisory Mechanism and a different crisis‑management playbook. Either path entails fresh complexity, but both could relieve the Swiss add‑ons that Cevian objects to.

Operationally, Zurich would remain a critical hub for wealth management, technology, and risk functions. A legal move need not mean an exodus of staff, nor a retreat from Swiss clients. But the symbolism would be profound: a tacit judgment that the cost of being “Swiss‑too‑big‑to‑fail” outweighs the benefits of a Swiss parent.

The decision facing the board
UBS’s directors face a finely balanced call. The bank has spent the past two years integrating Credit Suisse, deleveraging risk‑weighted assets, and rebuilding confidence with clients. Management will be wary of injecting avoidable uncertainty. At the same time, they must safeguard return on equity and a payout profile that underpins the share price. If the policy trajectory crystallizes into a durable capital gap, the case for redomiciling will be harder to ignore.

What happens next turns on whether Bern calibrates the final rules closer to global standards—or doubles down on a more conservative Swiss line. For now, Cevian’s message has landed: Switzerland’s reform has consequences that extend beyond technical capital ratios to the future of the country’s flagship bank, its financial center, and the politics of risk after Credit Suisse.

Key facts
• Cevian owns about 1.4% of UBS and says Switzerland’s proposals make it “not viable” to run a large international bank from the country.
• UBS could face up to roughly $26bn in additional capital under the blueprint now in play.
• Swiss lawmakers this month enabled the government to enact some capital‑quality changes by ordinance, while wider reforms proceed through Parliament.
• UBS says the package departs from international norms; Finma backs the thrust of the reform.
• A potential relocation—to the U.S. or an EU member state—would leave Zurich a major hub but move the parent company’s legal seat abroad.