Callstrike
Compliance

Voice phishing simulations in Switzerland

Phone numbers in SwitzerlandProvisioned by Callstrike after approval

Nothing you know about running a voice phishing simulation in the European Union transfers here, and that cuts both ways: the data protection route is cleaner than the European one, and the criminal and labour routes are markedly harder. Switzerland is not stricter or looser than its neighbours. The constraint simply sits somewhere else, and this page says where.

Phone numbers

Supplied by Callstrike

Local numbers in Switzerland, after a one-time approval.

Running a simulation

Permitted, if the purpose is resilience

Labour law prohibits systems aimed at watching how staff behave at work.

Consent

It solves a different problem

The labour prohibition is public law, so no agreement with staff can cure it.

Getting a phone number in Switzerland

One approval per country, completed in the console.

Provisioned by Callstrike after approval

Numbers here are not released from open inventory. Your workspace is cleared for this country once, and Callstrike then provisions a dedicated number against it for your simulations. Approval is a one-time, per-country step and usually takes 3 to 5 business days. We only ask for what the regulator requires.

Swiss numbers are not released from open inventory, so your workspace is cleared once and Callstrike then provisions a dedicated Swiss number against it. The clearance is register-based and short: the name and the registered office address, both taken from an extract of the commercial or official business register showing the local address, alongside the enterprise identification number.

The caller identity regime here is engineered against exactly the thing a pretext reaches for first, which is presenting the internal helpdesk number. A provider may let you present further numbers only where you can prove a right of use in them, must act to stop a customer presenting numbers it has no right to, and must coordinate to block a call carrying an invalid or unauthorised one. Since the middle of 2026 a transmitted number also carries an indicator of whether it rests on the customer's own data and whether the provider checked it, so a customer-supplied identity is visibly second class in the signalling and the downstream network can act on that.

  1. 01Complete the regulatory clearance formYour administrator, in the Callstrike console. The form asks only for what the regulator requires.
  2. 02Approval is granted against your workspaceTypically three to five business days, and once only for as long as you operate here.
  3. 03A dedicated number in Switzerland is assigned to youCallstrike
  4. 04Build and launch the campaignYour team
What you provideAccepted evidence, any one of
NameExcerpt from the commercial or official business register
Registered office addressExcerpt from the commercial or official business register showing the local address

These requirements are set by the carrier and can change. The form in the console is generated from their current rules, so treat it as authoritative and this table as a summary of what to have ready. Checked 2026-09-07.

Is it lawful to run a simulation in Switzerland?

The position in short, before your counsel reads the detail below.

Yes, and the first thing to get right is that none of the European framework reaches you. Switzerland is outside the European Union and outside the European Economic Area, having declined membership in 1992, and runs on bilateral agreements instead. The artificial intelligence regulation, the network and information security directive and the financial-sector resilience regulation are not Swiss law. Do not carry the answer across from Norway or Iceland either: their position turns on the Agreement Switzerland declined to join.

Data protection is the easy part, which surprises people. Swiss law does not work through a list of lawful bases at all: processing must not unlawfully breach the personality of the people concerned, and a breach is justified by agreement, by an overriding private or public interest, or by law. Better still, the statute expressly permits deferring or dispensing with the information duty where informing the person would defeat the purpose of the processing. That is a cleaner textual hook for a covert exercise than anything in the European Regulation, which reaches a similar result by a much longer route.

Recording is the sharp edge, and it runs opposite to most of Europe. A participant who records a non-public conversation without the consent of the others taking part commits an offence carrying up to a year, and the same provision reaches keeping, evaluating or passing on such a recording. The statutory exemption looks like a lifeline and is not: it covers calls to assistance, rescue and security services, and in business dealings conversations whose content is orders, mandates and reservations. A simulated pretext call is neither. Anyone reasoning that Swiss business calls may be recorded has read the first half of the provision.

The labour rule is the one that decides what your programme is allowed to be. Monitoring and control systems intended to monitor the behaviour of employees at their workplace may not be used at all, and the state secretariat's guidance says the protection is public law and cannot be departed from by private agreement, whether with employees or with their organisations. Its worked example of prohibited behaviour monitoring names telephones with which employees' conversations can be listened to or recorded. An exercise measuring organisational resilience, declared in advance, is arguable under the federal court's test. One that scores named individuals into performance or discipline is the thing the article prohibits, and no agreement fixes it.

What your company needs to do

6 items, in the order you will need them.

  • Build the file the labour inspectorate can ask forSwitzerland-specificThe deliverable here is not a submission to a telecoms regulator, it is a file you can produce on request: a written justification of the overriding interest, a proportionality analysis, a record of how employees were involved in planning, the operating times and retention, and an internal regulation telling staff what rights and duties apply where monitoring systems including telephony are used.
  • Frame the purpose as resilience, and hold the line internallySwitzerland-specificThe prohibition is on purpose rather than effect, and the federal court's test is whether the system aims exclusively or mainly at monitoring employee behaviour as such. That makes the internal argument about whether results ever feed a performance record a legal question rather than a cultural one. Settle it before the first campaign.
  • Do not solve this with an employment contract clauseSwitzerland-specificThe state secretariat is explicit that the protection is public law and that it is not permissible to depart from it by private agreement with employees or their organisations. A clause in the contract, or in a collective agreement, does not cure a system caught by the prohibition. It answers a different question.
  • Assume recording needs everyone's agreementSwitzerland-specificBeing on the call does not help, the exemption does not reach a security test, and a supervisor on a monitoring bridge is in the harder provision rather than the easier one. Ask whether the programme needs the audio at all; a campaign recording what happened and when does not have to solve this.
  • Use an invented persona, not a named colleagueSince September 2023 there has been an identity-misuse offence aimed at using another person's identity to harm them or to obtain an unlawful advantage. An authorised test normally lacks that intent, but if the scenario impersonates a named real colleague, that person's written agreement is the clean answer rather than an argument about intent.
  • Tell the people who would have to report an incidentOperators of listed critical infrastructure must report cyberattacks within 24 hours of discovery. A simulation is not an attack, but a test your security operations centre has not been told about can be escalated and reported as one, and unwinding a false report to a federal office is a worse afternoon than the test was worth.

The controls that do the work

How Callstrike is configured, and which provision in Switzerland each choice answers.

Auto-hangup before disclosure

The bot ends the call at the moment an employee starts to give up a credential or a piece of personal data, so the thing the pretext asked for is never spoken into the system and never stored.

The Swiss justification you write turns on an overriding private interest and on proportionality, and the labour guidance requires that justification in writing where security monitoring cannot be cleanly separated from behaviour monitoring. A call that ends the moment an employee starts to give up a credential is what makes that separation stateable: the exercise measures whether the organisation is resilient, and the credential the pretext asked for is never acquired at all, so there is no personal file being built out of it.

In-call debrief and follow-up

A second voice breaks character as soon as the call ends, explains what just happened and why it worked, and a follow-up email repeats it in writing while the moment is still sharp.

The federal court's test asks whether the system aims exclusively or mainly at monitoring employee behaviour as such, and a call that ends in immediate teaching is evidence about aim rather than a claim about it. A second voice breaking character on the spot, and vishing training in writing the same day, is also the part of the design that keeps the recording question small, because there is nothing worth replaying to a third party.

Consent Management

Two modes: collect consent now, over email, Slack or Teams with a full audit trail per employee; or record that your organisation already has this covered, by uploading the policy, handbook clause or agreement and confirming the scope it applies to. The document is hashed, the attestation is signed and timestamped, and an audit email is issued. Included on every plan.

Be precise about what this can and cannot do here. It cannot cure the labour prohibition, which is public law and not contractible around, and this page does not pretend otherwise. What it produces is the advance-notice half of the federal court's test, which turns partly on employees having been informed in advance that the system is in use, plus the record of how employees were involved in planning that the inspectorate file is supposed to contain.

SCORM module

An interactive web presentation on voice-phishing risk, delivered through your own LMS, which then invites the learner to opt into a web call with the bot. A call the person starts themselves in a browser is not a telephone call, so telephony rules do not reach it.

Switzerland has no duty to tell the person on the line that the voice is synthetic, and we report that as an absence rather than as permission, because it is the kind of absence that closes. Meanwhile Callstrike's vishing simulator can deliver the same deepfake voice through a web call the learner starts themselves after the module, and a call a person opens in their own browser presents no Swiss number, so the right-of-use rule and the blocking obligations have nothing to attach to.

Consent Management is included on every plan. See AI voice phishing simulation and human-in-the-loop voice phishing for how each is delivered.

For your legal team

The sourced position

Everything above, with the instruments behind it. Every claim cites the statute or the regulator it comes from, so your counsel can verify it rather than rely on our summary.

Swiss law asks a different question, so bring a different answer

Nothing on this page follows from the European framework, and that is the first thing to get right. Switzerland is not in the European Union and it is not in the European Economic Area either, having declined membership in 1992. Its relationship with the Union runs through bilateral agreements. So the instruments that carry most of the weight on our German or Dutch pages are simply not law here, and importing them would produce a confident wrong answer.

The Swiss data protection act does not work through a list of lawful bases at all. It says that whoever processes personal data must not unlawfully breach the personality of the people concerned, and that a breach is unlawful if it is not justified by the data subject's agreement, by an overriding private or public interest, or by law. The structure is permission unless breach, with justification available. An employer testing its own workforce for a genuine security purpose is arguing an overriding private interest, and it should write that argument down before the first call.

Two processing principles then do the real work. Data may be collected only for a specific purpose that is recognisable to the person concerned, and processing must be in good faith and proportionate. On the face of it recognisability is fatal to a covert exercise. It is not, and the reason is the most useful provision on this page: the act expressly permits a controller to restrict, defer or dispense with the information duty where informing the person would defeat the purpose of the processing. That is a cleaner textual hook for a covert test than anything in the European Regulation, which reaches a similar result by a longer route. The programme must still be recognisable in the sense that it is declared in advance as a programme; what may be deferred is the notice about the particular processing.

The employment overlay is short and strict. An employer may process data about an employee only insofar as they concern that employee's suitability for the employment relationship or are necessary to perform the contract. A simulation designed to measure organisational resilience sits comfortably inside that. A simulation designed to build a per-person file on who is gullible does not, and the distinction is worth settling internally before anyone runs a campaign.

Two documentation duties are concrete. An impact assessment must be prepared in advance where processing may entail a high risk to personality or fundamental rights, the regulator must be consulted where a high residual risk remains, and the assessment must be kept for at least two years after the processing ends. And nobody can waive the right of access in advance, so whatever per-employee results the programme generates are obtainable by the employee who asks.

The criminal provision that catches you even as a participant

This is the block that changes how a Swiss programme is designed, and it is the opposite of the answer most of Europe gives.

Being on the call does not help you. The criminal code provides that whoever, as a participant in a conversation, records a non-public conversation onto a sound carrier without the consent of the other people taking part is punished, on complaint, with custody of up to one year or a monetary penalty. The same provision catches keeping, evaluating or passing on a recording you know was made that way. So the ordinary one-party logic that makes recording routine in the United Kingdom or Ireland does not run here.

The neighbouring offence is worse and easier to trip by accident. Recording or listening to a conversation you are not part of requires the consent of everyone taking part and carries up to three years. A supervisor listening in on a monitoring bridge, or a platform component that is not sensibly described as a participant, is in the harder provision rather than the easier one. The severity runs opposite to intuition.

There is a statutory exemption and it looks like a lifeline until you read it. A participant or subscriber may record telephone conversations with assistance, rescue and security services, or, in business dealings, conversations whose content is orders, mandates, reservations and similar business transactions, and those recordings may be used only to prove something. A simulated pretext call is neither of those. Anyone reasoning that Swiss business calls may be recorded has read the first half of the provision and stopped.

Two further offences deserve naming because a simulation can walk into them. Misusing a telecommunications installation to alarm or harass is a complaint offence with a one-year ceiling, and it carries no marketing qualifier at all, so a pretext that genuinely distresses someone has a Swiss criminal provision waiting for it. And since September 2023 there has been an identity-misuse offence, aimed at using another person's identity to harm them or to obtain an unlawful advantage. An authorised test normally lacks that intent, but if your scenario impersonates a named real colleague, getting that colleague's agreement in writing is the clean answer.

The practical consequence is a design decision rather than a legal one. Ask whether the programme needs the audio at all. A campaign that records what happened and when, rather than the conversation itself, does not have to solve this problem.

No labelling duty here, and the reason matters

Switzerland has no equivalent of the European transparency rule for artificial voices. We looked for one across the data protection act, the unfair competition act, the criminal code and the telecommunications instruments, and there is none. The federal communications office describes the federal government's chosen path as ratifying the Council of Europe convention on artificial intelligence and making sector-specific adjustments, with a consultation draft due by the end of 2026. So there is no Swiss duty today to tell the person on the line that the voice is synthetic. We report that as an absence rather than as permission, because it is the kind of absence that closes.

What does exist is scoped to advertising, and that scoping is the whole answer to the automated-calling question. The unfair competition act makes it unfair to send mass advertising by telecommunications without prior agreement, correct sender details and a free opt-out; to ignore the directory marker by which someone has said they want no advertising from strangers; and to make advertising calls without displaying a number that is in the directory and that the caller is entitled to use. All three limbs say advertising on their face. An authorised test of your own staff is not advertising and is not a competitive act, so none of them reaches it.

There is a trap inside that good news. The third limb is the closest thing Swiss law has to an anti-spoofing rule aimed at the caller, and because it is scoped to advertising it does not govern your simulation. The rule that does govern it is in the telecommunications services ordinance and is described in the next section. A page that cited unfair competition law for the caller identification constraint would cite the wrong instrument and reach a falsely permissive conclusion.

Whether a live operator or a synthetic voice speaks makes no difference to any of the above, and we are not going to pretend otherwise. The Swiss provisions in play turn on purpose, on who recorded what, and on which number was presented. None of them turns on whether the speaker was a person. Where a synthetic voice does change the analysis is the identity-misuse offence, which is about whose identity you borrowed rather than how you produced the sound.

Present a number you can prove a right to, or be blocked

The Swiss caller identification regime is engineered against exactly the pattern a simulation reaches for first, which is presenting the internal helpdesk number.

The telecommunications services ordinance requires connection-originating providers to transmit the number allocated to the customer for the service being used, and forbids everyone else in the chain from altering it. A provider may let a customer present further numbers only where the customer can prove a right of use in them. Where a provider knows a customer is presenting numbers it has no right of use in, the provider must take suitable measures to stop it, and where a transmitted number is invalid or used without a right of use, providers must coordinate to prevent the transmission or block the call.

From the middle of 2026 there is a further wrinkle worth planning around. Transmitted numbers must carry an indicator showing whether they rest on the calling customer's own data or on the originating provider's information, and whether the provider checked them. The staged introduction reached mobile numbers on 1 July 2026. So a customer-supplied caller identity is now visibly second class in the signalling, and the downstream network can act on that. Numbers in the premium ranges may never be presented as a calling number at all.

Separately, the holder of an allocated number may use it only for the purposes fixed when it was allocated, and the state secretariat for economic affairs may, on reasonable suspicion of repeated unfair-competition breaches through a number, order a provider to block incoming connections to it and disclose the holder. That is worth knowing even though a simulation is not advertising: the block happens first and the argument that it was not advertising is made afterwards.

So the operational rule is simple to state and unforgiving. Originate from a number your organisation or its supplier genuinely holds. A spoofed Swiss number is not merely unlawful, it is something the network is instructed to stop.

What the country matrix holds for Switzerland

Number types:
Local
Restricted for automated outbound:
None recorded

Generated from the same country matrix the platform enforces at dispatch, so it cannot drift from what you can actually buy.

What you must be able to show the labour inspectorate

Switzerland's paperwork is not a submission to a telecoms regulator before you can buy a number. It is a file you must be able to produce to a cantonal labour inspectorate on request, and it is the thing most programmes here get wrong.

The health-protection ordinance provides that monitoring and control systems intended to monitor the behaviour of employees at their workplace may not be used, and that where such systems are necessary for other reasons they must be designed and arranged so that employees' health and freedom of movement are not impaired. Read the first paragraph carefully. It is a prohibition on purpose, not a balancing test, and it is public law.

The state secretariat's own guidance to that article is unusually direct on three points. It says the protection is public law and that it is therefore not permissible to depart from it by private agreement, whether between employer and employees or with their organisations, which means an employment-contract clause or a collective agreement cannot cure it. It lists, as an example of prohibited behaviour monitoring, microphones or telephones with which employees' conversations can be listened to or recorded or their voices analysed. And where performance or security monitoring cannot be cleanly separated from behaviour monitoring, it requires the business to examine and justify in writing its overriding interest and the proportionality of the planned system, and to produce that justification to the cantonal labour inspectorate on request, along with access to all documents and data of the systems operated.

So the file is the deliverable. Written justification of the overriding interest, a proportionality analysis, a record of how employees were involved in planning, installation, operating times and retention, and an internal regulation telling staff transparently what rights and duties they have where monitoring systems including telephony are used. The guidance also reproduces the federal court's test, which is that a system is prohibited where it aims exclusively or mainly at monitoring employee behaviour as such, and is not prohibited where it objectively has that effect but is justified by legitimate reasons such as security, provided it is proportionate and the employees were informed in advance of its use.

The honest reading, and we would rather give it than a comfortable one: a simulation measuring organisational resilience, declared in advance as a programme, is arguable under that test. A simulation that scores named individuals and feeds the scores into performance or discipline is the thing the article prohibits, and no amount of consent fixes it.

A reporting duty, a supervisor's circular, and no European overlay

The instruments that shape this section on our European pages have no application here. The Union's artificial intelligence regulation, its network and information security directive and its financial-sector digital resilience regulation are not Swiss law and do not reach a Swiss employer testing Swiss staff. Switzerland's overlays are its own and there are two.

The first is a reporting duty. Operators of listed critical infrastructure must ensure that cyberattacks on their information technology are reported to the federal office for cybersecurity, within 24 hours of discovery, where the attack endangers the functioning of the infrastructure, has led to manipulation or leakage of information, went undetected for a longer period, or is connected with extortion, threat or coercion. The list of covered bodies includes undertakings subject to the banking act, the insurance supervision act and the financial market infrastructure act, energy undertakings, hospitals on a cantonal list and universities. The duty has applied since 1 April 2025 and the enforcement provisions, including a fine of up to 100,000 francs for defying a final order, since 1 October 2025.

That duty is about incidents rather than exercises, and an authorised simulation is not an attack on the organisation. But there is a practical trap in it. A test that the security operations centre has not been told about can be escalated as a real attack and reported inside 24 hours, and unwinding a false report to a federal office is a worse afternoon than the test was worth. Tell the people who would have to make the report.

The second overlay is the financial supervisor's circular on operational risks and resilience for banks and securities firms, which requires risk-based scenario-related cyber exercises on the basis of institution-specific threat potentials, documented and reported, with table-top and red-teaming exercises offered as examples in a footnote. It also requires awareness measures for staff. It is worth being precise about what it does not say: a full-text search of the circular finds no mention of phishing, social engineering or vishing at all. Anyone telling you the Swiss supervisor requires voice phishing tests is selling, not citing.

Take this further

Research prompt for your own AI assistant

Paste into Claude, Harvey or your firm's tool to pressure-test the position above.

You are advising on an authorised internal security exercise in SWITZERLAND. Our own employees receive a simulated voice-phishing call, placed by our vendor on our instruction, to measure organisational resilience. No credential is captured or stored and no audio is recorded. Results are never individualised into performance records.

Verify or correct each proposition below against primary Swiss sources:

1. ⚠ Switzerland is in NEITHER the EU nor the EEA, so the AI Act, NIS2 and DORA are not Swiss law. Do not import the Norway or Iceland analysis.
2. DSG art 30 makes a breach of personality unlawful unless justified by consent, an overriding interest or law; ⚠ DSG art 20(3)(b) expressly permits deferring or dispensing with the information duty where informing would defeat the purpose.
3. OR art 328b limits employee data to suitability for the relationship or necessity for performing the contract.
4. ⚠ StGB art 179ter catches a PARTICIPANT who records a non-public conversation without the others' consent; art 179quinquies's exemption covers emergency services and transactional business dealings only. Confirm neither reaches a pretext call.
5. ⚠ ArGV 3 art 26(1) prohibits systems INTENDED to monitor employee behaviour, and the SECO Wegleitung states this is public law that cannot be departed from by private agreement. Advise on the federal court's aims test for a resilience exercise.
6. ⚠ FDV art 26a is IN FORCE. Its fedlex rendering carries a footnote reading 'Aufgehoben durch Ziff. I der V vom 6. Mai 2026', which repeals the MARGINAL NOTE only; all six paragraphs remain. Confirm, and confirm the mid-2026 attestation indicator staging.
7. StGB art 179decies (identity misuse, in force September 2023) and art 179septies (misuse of a telecommunications installation, no marketing qualifier).

Flag anything that has changed since September 2026, and tell me whether the federal AI consultation draft has been published.

Common questions

Can we record simulated calls in Switzerland?
Not without the employee's agreement. The criminal code catches a participant who records a non-public conversation without the consent of the others taking part, and the exemption covers emergency services and transactional business calls, not security tests. Consider whether your programme needs the audio at all.
Do the EU AI Act, NIS2 and DORA apply in Switzerland?
No. Switzerland is outside both the European Union and the European Economic Area, so those instruments are not Swiss law. Do not carry an answer across from Norway or Iceland either: their position turns on the EEA Agreement, which Switzerland declined to join in 1992.
Can we agree monitoring with staff in the employment contract?
Not for behaviour monitoring. The health-protection ordinance prohibits systems intended to monitor how employees behave at work, and the labour secretariat states that this protection is public law and cannot be departed from by private agreement with employees or their organisations. Consent solves a different problem.
Can we present an internal number the employee will recognise?
Only where you can prove a right of use in it. Providers must transmit the number allocated for the service, must stop customers presenting numbers they have no right to, and must block calls carrying an invalid or unauthorised number. A spoofed Swiss number is designed to fail rather than merely to be unlawful.

Elsewhere in Western Europe

The rules differ by country even inside one region. These are the nearest guides to this one, each showing how phone numbers are obtained there.