The case for anonymity is stronger than transparency advocates admit
It is easy, especially from an Anglo-American perspective, to treat named insider disclosure as obviously superior. Usually it is. But the Swiss position is not irrational, and critics should at least grapple with its best arguments.
Public naming can overshoot the regulatory aim
The purpose of management transaction disclosure is not to entertain the market with executive biography. It is to reduce information asymmetry and support confidence in fair dealing. If role, timing and transaction size already convey most of the economically relevant information, then naming may be an unnecessary increment in personal exposure.
That argument is strongest where the role itself is highly informative and the transaction is clearly routine. It is weakest where the role is generic and the transaction is potentially contentious.
Data permanence changes the stakes
When many disclosure regimes were designed, public records were public in a slightly quaint sense. They existed, but were not frictionlessly searchable, aggregated and republished forever. Today, a named insider filing can become a permanent part of a person's digital profile, scraped into commercial databases and context-stripped by social media.
Swiss caution looks less eccentric in that environment. A proportionality test in 2026 is not the same as a proportionality test in 1996.
There is a difference between supervisory transparency and public transparency
One can defend a system in which regulators and exchanges know the identity, while the public sees only a filtered version. That model says effective enforcement does not require universal publication of personal data. It requires competent authorities with full access and a credible willingness to act.
The obvious objection is that this asks the market to trust the referee and stop asking who committed the foul. Sometimes that is enough. Often it is not.
Where the Swiss model is most vulnerable
If the Swiss framework is going to be criticised, the criticism should be precise.
It creates uneven anonymity
A disclosure that names the exact role but not the person does not protect everyone equally. In a small-cap issuer, "CEO" may identify the person with near certainty. In a large-cap issuer, "member of executive management" may identify no one in particular. The privacy benefit therefore varies wildly by issuer size and governance structure.
That is not ideal policy design. Good disclosure rules should not depend for their privacy effect on how many people sit around the board table.
It weakens deterrence at the margin
Public naming is not just an information device. It is also a deterrent. The prospect of one's name appearing next to a badly timed or poorly explained trade can influence behaviour. Remove the name, and some of that reputational deterrence disappears.
No one should exaggerate this point. Serious insider-dealing deterrence comes from surveillance, enforcement and sanctions, not from embarrassment. Still, reputational discipline is part of the package.
It is out of step with international comparability
Global investors compare insider activity across jurisdictions. A Swiss filing and a French filing may both indicate a management transaction, but they are not equally informative. That hurts comparability, and comparability is one of the quiet virtues of harmonised disclosure standards.
For cross-border funds, this means Swiss insider data often needs a different interpretation layer. A screen that ranks named insider purchases in EU and US markets cannot simply ingest Swiss records as if they were equivalent. The data schema may line up. The informational content does not.
What reform would look like, if Switzerland wanted it
A full shift to named public disclosure would be the cleanest answer. It would also be the most politically difficult. Swiss legal culture tends to prefer calibrated solutions over grand transparency gestures.
Option one, name the person but raise thresholds or narrow categories
One plausible compromise would be to publish names only above a higher materiality threshold, or only for certain roles such as chair, CEO and CFO. That would preserve privacy for low-value or routine transactions while exposing the most market-relevant trades to full scrutiny.
The drawback is obvious. A two-tier system invites gaming around thresholds and creates more complexity.
Option two, publish persistent anonymous identifiers
A more elegant, if slightly nerdier, compromise would be to assign each reporting person a persistent pseudonymous identifier within an issuer, or even across issuers under regulator control. The market would not see the name, but it could observe whether the same person repeatedly buys or sells over time.
That would preserve some privacy while restoring behavioural analysis. It would also acknowledge the basic truth that the value of insider data lies partly in sequence, not just in single events.
Option three, keep anonymity but improve metadata
If Switzerland insists on not naming individuals, it could at least improve the informational content of the role field and transaction context. Distinguish chair from ordinary director. Distinguish open-market trades from option exercises and related disposals. Standardise reason codes. Improve machine readability and archive access.
This would not solve the identity problem. It would, however, reduce some of the current ambiguity.