23.2.2026
SL Insight Newsletter #21
KP2 consultation: “Net firewall” instead of MFN protection
Marcel Boller
On February 19, 2026, the Federal Council opened the consultation process on the implementation of the second cost containment package. In terms of content, the package is primarily "domestic policy": APV/TQV will be refined, pricing models and confidentiality will be enshrined in law, and volume clawbacks will be prepared (cost consequence models; announced for 2029).
What does the bill say about MFN?
The report does not contain a single mechanism that mitigates Switzerland's status as an external reference country (neither GDP-PPP nor "US spill-over" are addressed). The adjusted confidentiality architecture is the only real MFN lever.
MFN risk remains
For companies, the core risk remains: GDP-PPP-based US reference logic typically ties in with the visible Swiss price anchor; refinements to APV/TQV push this further down. In practice, the line of defense is shifting even more strongly toward "high list/low net" – with the corresponding governance and leak risk.
