Why Does the SSA Oppose the Proposed Revisions to Switzerland’s Surveillance Laws?

Switzerland has long been recognised as a global centre for innovation and entrepreneurship. However, proposed revisions to two key federal surveillance ordinances—the VÜPF and VD-ÜPF—now pose a serious threat to the country’s startup ecosystem, its competitiveness, and its international reputation.

The Swiss Startup Association, representing over 800 startups across Switzerland, has submitted a formal statement to the Federal Department of Justice and Police (EJPD) opposing these revisions in their current form.

Overview of the Proposed Changes

The proposed revision would significantly expand surveillance obligations for technology companies operating in Switzerland. Specifically, internet-based communication services with over 5,000 users would be subject to new requirements related to real-time data delivery, extended data storage, and the provision of location and IP information. For larger companies—those exceeding 1 million users or CHF 100 million in annual revenue—these obligations would become even more extensive and financially burdensome.

Key Concerns for the Startup Ecosystem

1. Disproportionate Burden on Early-Stage Companies
The revised thresholds are so low that many startups would be affected while still in their initial development phases. Complying with the proposed legal and technical requirements would incur costs that are simply not viable for early-stage ventures. For companies in the growth phase, the increased administrative and infrastructure demands could significantly hinder expansion efforts.

2. Loss of International Competitiveness
Switzerland has cultivated its position as a digital innovation hub by maintaining favourable regulatory conditions. By introducing surveillance obligations that far exceed those in other Western nations, Switzerland risks driving its most promising startups abroad. Services such as VPNs, for instance, would be fundamentally incompatible with the proposed rules, eliminating entire business models and discouraging international entrants.

3. Reputational Risk to Switzerland as a Business Location
Switzerland’s appeal to global entrepreneurs and investors lies in its political neutrality, high-quality education institutions, and business-friendly environment. These proposed surveillance measures threaten to erode that trust. If enacted, the country could lose its standing as a safe and attractive destination for technology and innovation-based enterprises.

4. Increased Risk of Cybersecurity Threats
The obligation to store sensitive user data for extended periods across large datasets makes technology companies more vulnerable to cyberattacks. Such concentrated data repositories present a clear risk to both public safety and Switzerland’s broader economic interests.

The Swiss Startup Association’s Position

In our submission to the EJPD, we have called for a complete rejection of the proposed revisions to the VÜPF and VD-ÜPF. We believe the changes present an unacceptable risk to Switzerland’s economic vitality, startup ecosystem, and international standing. Our position is informed by direct dialogue with our members, the vast majority of whom are early-stage and growth-phase companies actively contributing to Switzerland’s innovation economy.

Call to Action

We welcome continued dialogue with policymakers and remain committed to supporting a legal framework that balances national security with the need for economic progress and digital freedom.

Startups, investors, and ecosystem stakeholders who wish to support our position or share their views are encouraged to contact us directly at info@swissstartupassociation.ch.

Together, we can ensure that Switzerland remains a place where innovation thrives.

Our Commitment to the Startup Ecosystem

At the Swiss Startup Association, we aim to support and strengthen Switzerland’s position as a leading innovation hub. We believe the future of Swiss entrepreneurship depends on maintaining a stable, predictable, and business-friendly environment. That’s why we are encouraging dialogue and awareness around the Enteignungsinitiative and its potential effects on startups.

We invite everyone in our community to stay informed, stay engaged, and help ensure that Switzerland remains a place where innovation and entrepreneurship can thrive.