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In brief

The Federal Information Security Act (ISA), which only entered into force on 1 January 2024 is already being amended with an obligation to report cyberattacks for operators of critical infrastructures. The term “critical infrastructures” is defined in a broad manner and captures many private companies. On 18 January 2024, the deadline for challenging the amendment by way of a public referendum expired. This means that the amended version (“revISA“) will become law, with the new obligation to report cyberattacks expected to come into force in 2025, although an exact date has not yet been set.  

In this alert, we address the most pressing questions around this new reporting obligation and provide you with important takeaways.


Click here to read the full alert.

Author

Alessandro Celli’s broad experience includes technology-related transaction work, intellectual property and competition law, IT, data protection and cyber risk, commercial litigation, sports and entertainment law. Alessandro regularly advises Swiss and international clients on technology-related national and cross-border transactions (JVs, licences, distribution, sale and purchase of technology or related businesses and brands). He counsels on sourcing and data protection, competition law and business restructuring as well as sports and entertainment law in relation to media or sponsoring. As a member of the IP and Disputes practice groups, Alessandro is leading the IT/C (TMT) team in our Zurich office. His actual focus lies primarily on new technologies and business processes within a digitalized global economy and the associated legal and compliance challenges. His work has been increasingly determined by co-operational (sourcing) work as well as regulatory items involving the rapidly developing new technologies with a large impact also on the financial services sector. Alessandro has chaired the committee on legislation and practice at the Zurich Bar Association and is a member of the boards of selected Swiss companies.

Author

Christoph Kurth heads the Investigations, Compliance & Ethics practice of the Swiss offices. Further, he is a member of the EMEA Steering Committee Compliance & Investigations and co-leads the EMEA Financial Institutions Industry Group. He has been recognized by Legal 500 as a leading individual for compliance, regulatory and investigation matters. Before joining the Firm, Christoph was global head of Litigation & Investigations and general counsel in Asia for a large Swiss bank. For over 10 years, he has led complex regulatory and criminal investigations as well as high stakes litigation across the US, Europe and Asia, and has advised on transformational regulatory developments and wealth management products and services across Switzerland and Asia. In his roles, Christoph has worked closely with business leaders, government authorities and the media, navigating businesses through regulatory and other challenges. Prior to this, Christoph was a litigator in leading practices in Switzerland and the US. Christoph also teaches post-graduate courses in 'Crisis Management' and 'Risk Governance' at the Europa Institute at the University of Zurich.

Author

Julia is a partner in Baker McKenzie's IP and Technology team. She is specialized in IP transactional matters with a particular focus on the healthcare industry. Prior to joining Baker McKenzie, Julia worked for major law firms in Munich and New York City, and as a lecturer and research associate at the University of Konstanz. In 2018, she was seconded to Novartis. Julia has been ranked as a "rising star" for Life Sciences in Switzerland by Legal 500, and for Intellectual Property by Managing IP. Julia is heavily involved in the Firm's children's rights pro bono work.

Author

Eva-Maria Strobel is a partner in Baker McKenzie's Zurich office. She is a member in the Firm's global IPTech Practice Group, chairs the EMEA IPTech Practice Group and heads the Swiss IPTech team. Eva-Maria is admitted to the bars in Switzerland and Germany, and worked in the Firm's Frankfurt office prior to relocating to Zurich. Legal 500, Chambers, WIPR, Managing IP and WTR 1000 praise Eva-Maria as one of the leading trademark lawyers in Switzerland.

Author

Johanna Moesch is an associate in the Firm’s Intellectual Property Practice Group in Zurich. Prior to joining Baker McKenzie she worked as an associate and senior associate in a major Zurich law firm and prior thereto as a law clerk in a Swiss district court. She was also a tutor and student research assistant at the University of Basel in the fields of public and private law. Johanna obtained a LL.M. degree from the Tsinghua University (Beijing). She is a member of the International Association of Privacy Professionals (IAPP) and since January 2021 a Certified Information Privacy Professional/Europe (CIPP/E).

Author

Meera Rolaz is an associate at Baker McKenzie's Antitrust, EU & Trade Law and Compliance & Investigations Practice Groups in Zurich. She is also part of the Data & Technology team. After graduating from Oxford University with a Bachelor of Arts and a Master degree, she completed her LLB at the London University of Law and qualified as a UK solicitor in 2016. She worked over 7 years at Baker McKenzie in London and has spent time in the Amsterdam office before joining Baker McKenzie Zurich in 2022. Meera is bilingual in French and English.

Author

Nicole Schön is a member of Baker McKenzie's Intellectual Property & Technology practice group.
After being admitted to the bar Nicole joined Baker McKenzie as an associate. From August 2020 until June 2021 she completed the bilingual (French and English) LLM in European Law at the College of Europe in Bruges after which she worked for the attorney general's office in the area of cybercrime before rejoining Baker McKenzie in May 2023.