Switzerland
Switzerland · revFADP
Switzerland sits outside both the EU and the EEA, with its own regime: the revised Federal Act on Data Protection (revFADP). It tracks GDPR closely in spirit, but the differences matter — and Swiss companies moving data to the U.S. have their own transfer route to navigate.
What it covers
GDPR-aligned, but not identical
The revFADP, in force since September 2023, modernised Swiss data-protection law and brought it broadly into line with GDPR — lawful processing, records, information duties, and transfer restrictions. But it is a distinct statute, supervised by the Federal Data Protection and Information Commissioner (FDPIC), with its own scope and details.
Where it differs
The revFADP and GDPR diverge in areas such as the treatment of legal entities' data, specific documentation duties, and certain definitions. A Swiss company shouldn't assume its GDPR programme maps over one-to-one — the gaps need checking.
The Swiss–U.S. transfer route
Switzerland has its own adequacy and transfer framework, including the Swiss–U.S. Data Privacy Framework for certified U.S. recipients, alongside SCC-equivalent mechanisms. Privello helps Swiss companies pick and document the right route for transfers into the United States.
What Privello handles
- U.S.-side data-protection strategy for Swiss companies
- Swiss–U.S. transfer mechanisms, including the Swiss–U.S. DPF
- Mapping where a GDPR programme needs revFADP adjustments
- Coordination with qualified Swiss counsel on local-law questions
- Alignment with the immigration side of a U.S. expansion
See the transatlantic transfer toolkit
Common questions
Questions European companies ask
Is the revFADP the same as GDPR?
Closely aligned but not identical. The revFADP is a separate Swiss statute with its own scope and details, so a GDPR programme usually needs checking and some adjustment rather than a straight copy.
How do Swiss companies transfer data to the U.S.?
Through Switzerland's own framework — including the Swiss–U.S. Data Privacy Framework for certified recipients — or SCC-equivalent mechanisms with an assessment behind them.
Does Privello practise Swiss law?
No. Privello handles U.S.-side data-protection and immigration work and coordinates qualified Swiss counsel where Swiss law governs.
Begin
Talk through your move with Privello
Tell us what you're planning. We'll outline the realistic options — and how the immigration and data-protection steps line up — in a first conversation.