Risk Culture: The Evidence Gap
Risk Culture Survey 2026
Why behaviour, not policy, is becoming the decisive test for banks in Europe and Switzerland
Geopolitical volatility and accelerating technological change are reshaping risk faster than policies and controls can keep pace. In this environment, risk culture is the only true line of defence: the collective judgement and behaviour that determine whether people identify, challenge and act on risk when it matters. The challenge for financial institutions is no longer defining the right culture on paper but proving that it works in practice, evidencing that those charged with governance can effectively live up to regulators' expectations of adequate business conduct.
How comfortable are you?
Why risk culture matters
Supervisory experience is unambiguous. The Swiss Financial Market Supervisory Authority (FINMA) observes that problems at distressed financial institutions often start with weak governance and poor risk culture, which then surface as an unsustainable business model. In its Annual Report 2025, FINMA states that a weak risk culture and an inadequate understanding of management responsibility are often at the root of breaches of supervisory law 2. In the European Union (EU), roughly 70% of European Central Bank (ECB) supervisory observations related to governance in the 2024 and 2025 cycles appear linked to risk culture dimensions, and between 77% and 86% of banks scored 3 or 4 on governance in recent Supervisory Review and Evaluation Process (SREP) results 1.
What the PwC Risk Culture Survey 2026 shows
The PwC Risk Culture Survey 2026 gathered responses from 47 European banking institutions across 12 countries, 72% of them ECB supervised 1. Its headline: a sector strong on frameworks but weaker on evidence of impact. The findings follow the four pillars first set out by the Financial Stability Board in 2014 1.
Tone from the top (7.2/10) Boards communicate goals and values well (7.7), but risk appetite does not reach all levels of the organisation (6.9) 1. |
Accountability (7.0/10) Training effectiveness is the weakest score in the survey (6.2): staff complete training, yet behaviour does not change where it matters. Risk ownership is often stated rather than lived in the first line 1. |
Communication Information flow and speak up channels rate adequately (both 7.6), but constructive challenge lags (7.0), and formal challenge mechanisms exist but are rarely used 1. |
Incentives Remuneration alignment and ethical standards under revenue pressure score highest (both 7.9), while the link between performance or promotion decisions and risk culture is among the weakest results (6.6) 1. |
Measurement remains the weak link. Evidence rarely goes beyond policy statements and training completion rates, and without evidence there is no proof of change.
The regulatory trajectory
In the EU, the European Banking Authority (EBA) consulted on revised Guidelines on Internal Governance under the sixth Capital Requirements Directive (CRD VI) in 2025, with final guidelines expected in Q4 2026 1. The ECB withdrew its 2024 Draft Guide on Governance and Risk Culture in favour of a good practices report planned for Q1 2027 1. This is not a relaxation: supervisors will look for concrete evidence of effective implementation rather than documented frameworks 1.
Switzerland is moving in the same direction. FINMA names governance, risk culture and risk management as an overarching supervisory focus in its Risk Monitor 2025 4. Under Circular 2017/1, the board of directors defines the guiding principles for the institution’s corporate culture 5. It is clear that responsibility lies with the institutions: the board of directors and executive board must implement a well developed risk culture and reflect the firm's values in their own conduct and decisions 3. FINMA intervenes early where this is not the case 6. Its 2025 on site inspections of seven banks echo the PwC findings closely. Governance and risk culture indicators were collected only sporadically and rarely reached senior bodies, board minutes did not show whether real discussion or dissent took place, and variable pay was not always aligned with employee appraisals, which FINMA says undermines a healthy risk culture 2.
Legislative change will raise the bar further. On 12 August 2026, the Federal Council opened a consultation, running until 19 November 2026, proposing a senior managers regime for banks with 250 or more employees, explicitly to improve corporate and risk culture, together with remuneration principles for all banks and clawbacks for top managers at systemically important banks 7.
Priorities for financial institutions
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Measure what matters: combine leading, lagging and perception indicators and report them to the board quarterly. |
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Change behaviour, not completion rates: replace tick box online learning with scenario based, role specific formats. |
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Make culture count in careers: embed risk behaviours in performance and promotion criteria, with formal conduct reviews for senior roles. |
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Cascade risk appetite: translate the enterprise statement into business line limits that front line staff understand. |
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Document challenge: ensure minutes capture substantive debate and dissenting views, as FINMA expects2. |
The message from supervisors in Frankfurt and Bern is the same: culture must be proven, not merely described. Institutions that build credible evidence now will be best placed for the next supervisory cycle.
Join our risk culture roadshow
To take the discussion further, PwC will hold a risk culture roadshow. During the roadshow we will present the results of the PwC Risk Culture Survey 2026 in more detail, share leading practices observed across participating institutions and discuss any questions you may have about strengthening risk culture in your organisation. We look forward to the exchange.
Contact us
Partner, Leader Financial Services Risk Consulting & Internal Audit, PwC Switzerland
+41 58 792 46 28
Fabienne Wikler