Switzerland's implementation of the OECD's CARF is a lesson in why this site keeps status marks. The revised AEOI act is formally in force since 1 January 2026 — parliament approved it in September 2025. But the list of 74 intended partner states is still in deliberation, and without it nothing runs: per the authorities, the crypto provisions find no application in 2026. Swiss providers are not collecting this year; realistically, collection starts in 2027 at the earliest and the first exchange in 2028 at the earliest. Every one of those dates can move — and that is precisely the information.
What is fixed, what floats
Fixed: the legal basis, the circle of reporting providers (exchanges, brokers, custodians), the content of reports (identity, tax residence, holdings, transactions) and the direction — Switzerland will exchange. Fixed, too, is who is missing: the USA, China and Saudi Arabia are not on the proposed list. Floating: the start year of collection, and with it of exchange, hanging on the parliamentary calendar for the partner-state list. We will update the line when the calendar sets.
The asymmetry already running
The deferral is not an all-clear, because it applies only to the Swiss end of the pipe. EU platforms have been recording their customers since 1 January 2026 under DAC8 — including customers resident in Switzerland. That data sits ready with EU authorities and will flow to Switzerland once the exchange activates — retroactively, covering what was collected. Trade through an EU exchange and you are already being recorded; the only open question is when the FTA reads it. For the cantonal offices, the reconciliation against the securities register then begins — and every discrepancy is grounds for proceedings.
Deferred does not mean cancelled. It means: the data ripens abroad while the Swiss end of the pipe is still being laid.
What this does to the one-time door
The penalty-free disclosure requires that the evasion be unknown to the authorities. The Swiss delay lengthens that window — and dates it: with the first exchange wave, "unknown" becomes "on file" for many foreign accounts, and the one-time door closes for precisely the years it could have healed. Holders of never-declared assets are not negotiating with a deadline but with a parliamentary calendar — and it is public.
The honest read
- The cleanly declared: document, done. Keep holdings and receipts, and future reconciliations are answered with an export.
- Users of EU platforms: you are already in the system. The self-certification with Swiss tax residence your exchange demanded is the proof.
- The never-declared: the window is open and dated. Reconstruction and disclosure before the first wave — after it, the data reconciliation decides, not the holder.
- Subscribe to this line, don't memorise it. The dates move; the change log tracks them.
A position note on a reporting system before its first cycle; dates may move. It is not advice, and reading it creates no professional relationship.