What Changed
- Federal Administrative Court confirmed that publishing debtor personal data to locate them or warn third parties breaches personality rights.
- Digitec Galaxus implemented an FDPIC recommendation enabling a one-click opt-out for website personalisation.
- FDPIC submitted consultation responses on federal legislative reforms involving the Banking Act, Telecommunications Act, and federal police systems.
The Federal Data Protection and Information Commissioner (FDPIC) of Switzerland published a series of updates between October 2025 and September 2026 detailing enforcement actions, legal opinions, and public guidance under the Federal Act on Data Protection (FDPA). These developments affect businesses operating in Switzerland, debt collection agencies, e-commerce entities, transport operators, and financial institutions.
In court and administrative proceedings, the Federal Administrative Court on 20 August 2026 (rendered on 22 June 2026) dismissed an appeal by Inkasso-Team AG. The judgment confirmed FDPIC practice that publishing personal data to locate alleged debtors or warn third parties breaches personality rights and cannot be justified. On 20 October 2025, the court also dismissed an appeal by citizens' association 'Bürgerforum Schweiz' against an FDPIC processing ban. Additionally, on 26 June 2026, the FDPIC concluded investigation proceedings into Cream della Cream Switzerland GmbH and Philipp Plein International AG following a 17 April 2026 ruling. On 26 February 2026, the authority opened an investigation under Article 49 et seq. FDPA into BLT Baselland Transport AG concerning train attendants' use of bodycams.
On compliance and guidance, Digitec Galaxus implemented an FDPIC recommendation on 12 February 2026 (issued 27 November 2025) allowing a one-click opt-out for personalization. The FDPIC issued factsheets on cookies, guidance on wearable privacy risks, warnings against fraudulent emails mimicking the FDPIC, and a joint global statement on AI-generated images with 60 other national data protection authorities.
Regarding legislative developments, the FDPIC issued formal statements on consultations modifying the Banking Act to strengthen 'too big to fail' rules, partial revisions to the Telecommunications Act (TCA), and proposed constitutional and statutory revisions allowing fedpol to operate a federal and cantonal police query platform.
Who May Be Affected
Companies operating in Switzerland, e-commerce retailers, debt collection services, transport operators, website managers, and financial institutions.
Cross-Border Context
Cross-border businesses targeting Swiss consumers or processing Swiss personal data must comply with FDPIC standards on opt-outs and data publishing bans, alongside participating in multi-jurisdictional initiatives like global joint guidance on AI-generated images.
What to check next
- Review specific Federal Administrative Court judgment texts regarding debtor data publishing.
- Monitor Federal Council updates regarding final drafts of the Banking Act and Telecommunications Act revisions.
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.
Prepared automatically with AI assistance from the official sources linked on this page. Translations and explanations do not replace the official text.