Clarity
Citizens should understand what is prohibited and what qualifies as an exception.
INTERNATIONAL COMPARISON · SWITZERLAND · GERMANY
Debt brakes: what France can learn from Switzerland and Germany
Updated comparison of Swiss and German fiscal rules and lessons for a French framework.
Switzerland: a rule that still changes budget decisions
The Swiss debt brake adjusts expenditure to revenue and the economic cycle. Structural deviations feed compensation mechanisms. In April 2026 the Federal Council again announced targeted cuts to comply with the rule for the 2027 budget, showing that it is an operational constraint rather than a decorative principle.
Official source: Swiss Federal Finance Administration.
Germany: 0.35% remains, but the rule has changed
Article 115 of the Basic Law still states the federal borrowing benchmark of 0.35% of nominal GDP. Since the 2025 reform, however, certain defence, civil-protection, intelligence, IT-security and assistance expenditure above 1% of GDP is removed from the relevant borrowing calculation.
Important update: a serious French comparison can no longer describe Germany’s rule as unchanged since 2009.
Current text: Basic Law, Article 115.
A French model should combine three qualities
Counter-cyclicality
The rule should not mechanically impose austerity at the worst point of a recession.
Legal force
A non-compliant budget must be blocked or corrected, not merely criticised in a report.
Legal and institutional sources
French Constitution, Article 20 — Government role.
Article 24 and Article 47 — Parliament and finance bills.
Article 26 — parliamentary non-liability for opinions and votes.
Article 67 and Article 68-1 — President and Government criminal regimes.
Financial Courts Code L.131-2, L.131-9 and sanctions L.131-16 et seq.
HCFP official missions; Swiss debt brake; German Basic Law Article 115.
Return to the project’s core framework
This page is part of the package on constitutional fiscal rules and accountability of public decision-makers.