Non-listed Swiss investments

New investment category

At its meeting on 17 November 2021, the Federal Council decided to create a new investment category for unlisted investments. From 1 January 2022, non-listed Swiss investments can be treated as a separate category in the catalogue of permitted investments for pension funds, with a ceiling of 5 percent of assets. Previously, such investments had to be categorised as alternative investments, subject to a maximum of 15 percent. The extent to which a pension fund is able and willing to make use of the limit depends on its risk capacity. The responsibility for this continues to lie exclusively with the responsible body of the pension fund.

The Federal Council is introducing this new investment category with amendments to the Ordinance on Occupational Retirement, Survivors’ and Disability Pension Plans (OPP 2) and the Ordinance on Investment Foundations (ASV), which will enter into force on 1 January 2022. It thus fulfils the core concern of the motion “Long-term investments of pension funds in future technologies and creation of a Swiss Future Fund” (13.4184) by former Council of States member Konrad Graber. The following can be understood from the explanatory notes to the amendment: Pension funds may continue to list non-listed Swiss investments under the category of alternative investments in accordance with OPP Article 53 para. 1 let. e if they prefer to do so. The amendment to the Ordinance does not result in a compulsory adjustment for institutions. The new category is therefore intended to open up new opportunities for pension funds.


Since the reform of the SNB is not moving forward, minor adjustments are to be expected. Unfortunately, this results in a patchwork. A new investment option also improves diversification, which we welcome. As with every investment, it is important to determine its suitability for the pension fund. Since risk capital is involved, a careful evaluation is indispensable. Complementa’s consultants will be happy to advise the decision-makers.

Heinz B. Rothacher, Chief Executive Officer

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