Two standards, 26 cantons · Part 14 of 14
14 · Predictions — class, grade, falsifier
Anyone writing about a development has to say what they expect, how certain they are, and how a reader would tell that they had got it wrong. Everything else is commentary. The thirteen chapters before this one counted, quoted, and dated; this chapter sets out what follows from the count, and binds itself to a rule that makes it less comfortable than it need be.
The rule, and where it comes from
The rule does not come from the tax world. It comes from a reassessment of a well-known forecasting text. Twenty-five months after publication we held Leopold Aschenbrenner's Situational Awareness against reality, claim by claim, and counted the result: 2 HIT · 1 PARTIAL · 3 MISS · 3 TOO-EARLY. Nine claims: two borne out, three wrong, and three not yet decidable when we ran the check.
The hit rate is not the interesting part. The interesting part is that the distribution was not random. The hits all sat on one kind of claim: the extrapolation of a measured quantity — compute, power consumption, and geopolitical attention. The misses sat, just as uniformly, on another: a threshold to be reached by a given date. Extend a curve and you were right. Name the date on which it crosses a given height and you were wrong, however good the argument.
The sentence that passed from there into our confidence rubric reads:
«Inputs extrapolieren, Outcomes nicht.» (extrapolate inputs, not outcomes)
— the system's confidence rubric, § «Forecast-class ceiling», introduced 01.08.2026
Three ceilings follow from it, and they hold throughout this text without exception:
- Trend extrapolation on a measured input can reach grade A. The condition: the input is a number we counted ourselves, with a date and a method attached.
- Threshold-by-date caps at B, however strong the argument. Not «B, wenn das Argument mittelmässig ist» (B if the argument is mediocre) — B as the ceiling, which a very good argument does not lift. That is the point of the rule.
- Category disappearance — the claim that something ceases to exist — caps at C unless a structural forcing mechanism is named. Where one is named, and it is published and dated, B is within reach.
A rule followed only when it delivers the result one wants is not a rule. So we say it here plainly: for P2 and P5 below, a case could be made that the evidence base is stronger than the grade. We do not make it. Nothing does more for the credibility of this text than applying our own rule in the open, at exactly the point where it costs us something.
The format
Every prediction sits in a single row of five columns: claim · class · grade · falsifier including test method and test source · test date. No prediction without all five. A falsifier that names no test source is decoration, since nobody can apply it. A missing test date leaves the claim unfalsifiable, because it could still come true at any point.
The eleven predictions
Group 1 — Zürich
| No. | Claim | Class | Grade | Falsifier (method · source) | Test date |
|---|---|---|---|---|---|
| P1 | On 30.09.2026, when the filing deadline for the 2025 tax period expires, neither the Wegleitung 505 for the 2025 tax period nor the ZHcorporateTax Hilfe-Center nor any of the crawled zh.ch pages for legal entities contains instructions for importing an E-Bilanz — measured as zero word-boundary hits for «E-Bilanz», «XBRL», «eCH-0276», «CH-Taxonomie», and «Instanzdokument». | Threshold-by-date | B | A zh.ch article, a Wegleitung supplement, or a Hilfe-Center article published before 30.09.2026 that contains at least one of the five strings at word-boundary precision. Method: the same regex, the same URLs, and the same Zendesk extract as in the baseline. Source: zh-support.etax.ch (Zendesk REST, 70 articles, all eight terms 0), zh.ch JP page and migration page (both all eight 0). | 30.09.2026 |
| P5 | Before 31.12.2027 the Kanton Zürich operates no interface usable in production for filing a legal-entity tax return from third-party software. | Threshold-by-date | B | A cantonal or vendor publication shows a JP interface for Zürich usable in production before the cut-off date; or LS 631.121 is amended to that effect; or the kantonales Steueramt issues a usage rule under § 13 Abs. 1 that opens the channel. Source: zh.ch, the Zürcher Steuerbuch, and the canton matrix of the vendor helpdesk (article 115000806069). | 31.12.2027 |
| P6 | Should the channel for third-party applications be opened for legal entities in Zürich, entry in the Treuhänder-Register under § 12 LS 631.121 is the published condition of access. | Threshold-by-date | B | An opening whose published condition is something other than the register entry. Source: LS 631.121 in the version then in force, together with the access conditions on the website of the kantonales Steueramt to which § 5 of the Verordnung refers. | 31.12.2027 |
| P10 | The number of legal entities liable to tax in the Kanton Zürich is above 100'000 for 2026. | Trend extrapolation on a measured input | A | The official Zürich figure for 2026 comes in below 100'000. Measured base: «Im Jahr 2024 waren im Kanton Zürich rund 97'000 juristische Personen … steuerpflichtig – rund 16 Prozent mehr als noch fünf Jahre zuvor» (in 2024 around 97'000 legal entities in the Kanton Zürich were liable to tax – around 16 per cent more than five years earlier) (media release of the Finanzdirektion, 18.07.2025), which works back to around 83'600 in 2019 and around +2'680 a year. Source: the cantonal publication of the figure. | 31.12.2027 |
P1 is the sharpest of the eleven, because it is settled soonest and because the date is the canton's own: slide 6 of the information event of 25.08.2025 carries the heading «E-Bilanz ab Steuerperiode 2025» (E-Bilanz from tax period 2025). The Wegleitung 505 for that same tax period names ZHcorporateTax seven times and the E-Bilanz not once. We do not claim the import is not coming. We claim that no instructions for it are published by the time the deadline expires, and we say how to prove us wrong.
P10 is the only one of the four to carry an A, and it is deliberately the dullest of them. A number that has risen by roughly 2'680 a year for five years is very likely to rise again in the sixth. That is precisely what A is for.
Group 2 — the federal level, the standard, transmission
| No. | Claim | Class | Grade | Falsifier (method · source) | Test date |
|---|---|---|---|---|---|
| P2 | By 31.12.2027 no private — that is, non-cantonal — Deklarationslösung is connected to the Swissdec Distributor in production. | Threshold-by-date | B | swissdec publishes a contractual basis for connecting private Deklarationslösungen; or a non-cantonal provider shows a Swissdec certificate for eBILANZ; or the list of coupled institutions published on swissdec.ch under § 8.16 of the Transmitter-Richtlinien carries such a solution. Checked quarterly, the first check on 31.12.2026. | 31.12.2027 |
| P4 | eCH-0276 keeps moving: within twelve months of the end of the Vernehmlassung on 03.09.2026, a version appears whose set of elements differs from the V2.0.0 draft. | Trend extrapolation on a measured input | A | Between 03.09.2026 and 03.09.2027 no version appears whose element diff against eCH-0276-2-0-0.xsd is anything other than zero. Measured base: three versions in twenty months, two of them changing the element set — 13 removed and 15 new with the swissdec patch 1-0-4, 139 removed and 183 new with V2. Source: ech.ch, the eCH-0276 standard page. | 03.09.2027 |
| P8 | The next swissdec eBILANZ package version after release 20260306 either contains a TestCase element in its XML schemas or removes UC003 «Testmeldung kennzeichnen» (mark test message) from the Richtlinien. | Threshold-by-date | B | The next package version contains neither a TestCase element in any of the shipped schemas nor a removal of UC003. Method: the same grep across all shipped XSD and SOAP examples; base 0 of 35 XSD and 0 of 11 examples on 04.08.2026. Named forcing mechanism: AB-11 makes the test-case marking mandatory, and certification under [TFBASIS] tests functionality — an obligation that cannot be implemented does not pass certification. Source: swissdec.ch, the eBILANZ document repository. | 31.12.2027 |
| P11 | Project INM2.084 in the implementation plan of Digitale Verwaltung Schweiz reaches its end date of 31.12.2026 without measures M3 «Umsetzung in Pilotkantonen» (implementation in pilot cantons) and M5 «Umsetzung Pilot mit MWST-Verwaltung und Swissdec» (pilot implementation with the MWST administration and Swissdec) completed. | Threshold-by-date | B | The next published DVS implementation plan shows both M3 and M5 as completed with a date on or before 31.12.2026. Evidence base today: neither measure is marked as completed in the 2026 plan, adopted on 27.10.2025, while M1, M2, and M4 are; the budget line carries CHF 0 for 2027. Source: the implementation plan of Digitale Verwaltung Schweiz, § 3.12. | 30.06.2027 |
P4 is the second A prediction, and it is one for the same reason as P10: it extends a curve we counted. Three versions of the same standard in twenty months, two of them with a changed set of elements, and an element diff we computed ourselves. We do not say what the next version looks like. We say only that it moves.
P8 needs a note on its grade. A case could be made that a forcing mechanism is named here and that the ceiling therefore does not bite. It bites all the same, because in its form the claim is a threshold with a date: it says when something happens. A forcing mechanism lifts a C prediction to B; it does not lift a B prediction to A.
Group 3 — Switzerland as a whole
| No. | Claim | Class | Grade | Falsifier (method · source) | Test date |
|---|---|---|---|---|---|
| P3 | The gap between the connection of natural persons (25 of 26 cantons) and of legal entities (14 of 26) for electronic transmission from third-party software narrows further, and stands at no more than six cantons on 31.12.2027. | Trend extrapolation on a measured input | A | The same vendor canton matrix, counted again across all 26 canton rows on the cut-off date, shows a gap of seven or more cantons. Measured base: 14/26 JP and 25/26 NP on 03.07.2026; Appenzell Ausserrhoden carries the note «Voraussichtlich ab 2026» (expected from 2026), and St. Gallen goes live in 2026. Test source: helpdesk article 115000806069, last edited 03.07.2026. | 31.12.2027 |
| P7 | The signed Jahresrechnung, as a PDF, remains a mandatory attachment in every canton that accepts an E-Bilanz, up to and including the filing round for the 2026 tax period. | Trend extrapolation on a measured input | A | A cantonal guide or Verordnung published before the cut-off date permits a JP tax return to be filed with a structured E-Bilanz and without the Jahresrechnung attached. A single such document falsifies it. Measured base: three cantons, three current documents with an explicit mandatory attachment, four productive tax periods in Obwalden with no counter-example, and the OR signature requirement for the Jahresrechnung that Zürich itself invokes. Source: the cantonal guidance documents themselves. | 31.12.2027 |
P3 is the prediction that gives this chapter its title, because it is the only one whose test source a third party runs and keeps up to date. We counted the matrix across all 26 canton rows on 03.07.2026; anyone counting it again on 31.12.2027 arrives, by the same method, at a figure that confirms us or refutes us. That is the difference between a prediction and an opinion.
P7 is our favourite of the eleven, because it cuts against the expectation the word «maschinenlesbar» (machine-readable) creates. Four productive tax periods in Obwalden, and the signed PDF Jahresrechnung has never disappeared. Nor has it in Appenzell Ausserrhoden, and Zürich invokes the Obligationenrecht for it. The structured file fills the form; it does not replace the document.
And the one C prediction
| No. | Claim | Class | Grade | Falsifier (method · source) | Test date |
|---|---|---|---|---|---|
| P9 | The paper route for the legal-entity tax return does not disappear in the Kanton Zürich before 31.12.2028. | Category disappearance | C | § 1 Abs. 3 LS 631.121 is repealed, or a Verordnung declares electronic filing mandatory for legal entities. Source: LS 631.121, zhlex, Nachtragsstand. | 31.12.2028 |
This prediction is expressly graded C, and the reason can be named: Zürich has published no forcing mechanism for the JP tax return. § 1 Abs. 3 of the Verordnung reads: «Die Steuererklärung kann auch in Papierform eingereicht werden.» (the tax return may also be filed on paper) No expiry date, no transition period, no announced repeal. Without a named mechanism the rubric caps at C, and C means: we state it, we mark it as weak, and we claim no more than the evidence carries.
Another canton shows what a published forcing mechanism looks like, and the comparison belongs here because it shows that the grade is a question of the record, not of temperament. Minutes of the Erfahrungsaustausch between the Steueramt of the Kanton Solothurn, EXPERTsuisse, and TREUHAND|SUISSE of 25.11.2025, Traktandum 10.1, verbatim:
«Fristverlängerungen • ab dem Kalenderjahr 2026 aus Dr. Tax online • ab dem Kalenderjahr 2027 nur noch online und via CSV-Datei • ab dem Kalenderjahr 2028 nur noch online übermittelt werden können.» (deadline extensions can be transmitted: from calendar year 2026 from Dr. Tax online; from calendar year 2027 only online and via CSV file; from calendar year 2028 only online)
That is a forcing mechanism: a sequence of stages with years attached, minuted and published. It covers deadline extensions, not the tax return, and it carries dates. For the JP tax return, Zürich has published nothing comparable. Hence C.
The verification infrastructure
Falsifiers nobody can check are rhetoric. Checking this text runs over the same ten sources, the same eight word-boundary terms, and the same baseline of 04.08.2026, 20:58 MESZ as the zero counts. The eight terms are eCH-0276, XBRL, E-?Bilanz, CH-Taxonomie|OR-Taxonomie, Instanzdokument*, swissdec, Schnittstelle*|API, and Drittsoftware*|Drittanwendung*. The count works on word boundaries, never on a substring: a naive search for ech returns ten hits in the Obwalden handbook, and all ten sit inside Jahresrechnung, Obligationenrecht, and entsprechend.
The rule the check reports by sits in the source code of the checking tool, and it applies to this chapter in exactly the same way:
«Silence means nothing changed — never that the check failed. A fetch failure is reported as
manual-check-due, never as green.»
And the qualifier from Part 12, which belongs here again because it would otherwise drop out exactly where it counts: the watch does not run on a schedule today. There is no entry in the scheduler, no cron line, and no entry in the register of expected runs. It has run once, to write the baseline. We may say: built, and given a baseline on 04.08.2026. We may not say: daily. Anyone who wants to check whether we run our own checks now holds the test source for that question.
What we do when we are wrong
Eleven predictions: six capped at B, four at A, and one at C. After the Aschenbrenner reassessment, some of them are to be expected not to come true, and the threshold-with-a-date ones ahead of the rest. So we say in advance what happens then.
This text is updated when the underlying material changes, not on a publication rhythm. There is no quarterly version and no annual edition. If a source changes, the text changes; if nothing changes, it stands.
Changes are recorded at the head of the document, with a date and with a note of which source moved.
A falsified prediction is left standing and marked as falsified, rather than deleted. Remove a prediction once it has turned out to be wrong and you publish, retrospectively, a better hit rate than you had. What this chapter is worth to a reader lies in exactly that: being able to read, two years from now, how often we were wrong and on which class of claim. We have done it elsewhere: one of our own notes of 04.08.2026 opens by recording that its predecessor's headline was falsified six days later by two primary sources. The predecessor is still there.
Three sentences to the cantons
What follows is opinion about the situation. It is marked as such, and it contains no statement about the conduct of any named person or authority.
First. The distinction between the two formats is settled cleanly in the technical material — the communication matrix of the Transmitter specification assigns each route its artefact — and it is not visible in the communication addressed to taxpayers. A short public statement of which artefact a portal accepts, in which version, and with which validation would close the open question from Part 8. We do not know what that would take: the list in the Solothurn minutes of 25.11.2025 shows six systems hanging on the introduction of a single standard. What we can say is which statement we are missing.
Second. The admission regime for private Deklarationslösungen is today a contractual matter, with a named holder and a «zuerst» (first):
«Aus vertragsrechtlichen und statuarischen Gründen seitens Swissdec können aktuell nur kantonseigene Deklarationslösungen die E-Bilanz via Distributor elektronisch empfangen. Für die Anbindung von privaten Deklarationslösungen an den Distributor müssen zuerst die vertraglichen Grundlagen geschaffen werden.» (for reasons of contract law and of swissdec's own articles of association, only cantonal Deklarationslösungen can currently receive the E-Bilanz electronically via the Distributor. To connect private Deklarationslösungen to the Distributor, the contractual foundations must first be created)
— Technische Spezifikation eBILANZ, Anforderungen Transmitter, release 06.03.2026, note immediately below Table 2.1
A «zuerst» presupposes a «dann» (then). A published timetable for that «dann» would be information, not a commitment. The difference is not a small one: information can be planned around, whereas its absence can only be waited out.
Third. A test marker that the Richtlinien require and the schemas do not contain is one to close before the first production call, rather than after it. The Richtlinien require it in § 8.1 and § 8.3; it appears in none of the 35 shipped schemas and in none of the 11 shipped SOAP examples, and the Job types are closed sequences with no extension point. Why we hold this to be the most important of the three sentences is set out in Part 10: in Germany we lost six returns because a missing test marker counted not as an error but as a live case. A missing test marking fails in exactly one direction: everything is production.
Two recommendations
To software vendors. The route open today is not only XBRL out of the accounting system. We put that too narrowly in an earlier version, and correct it here. The Regelwerk of the Schweizerische Steuerkonferenz (the Swiss Tax Conference), part of the eCH-0276 standard, names two electronic channels, in identical wording, for the Aktiven, Passiven, and Erfolgsrechnung dialogues:
«Wird die E-Bilanz elektronisch übermittelt (Upload oder via Swissdec), können die Positionen nicht überschrieben werden.» (if the E-Bilanz is transmitted electronically (upload or via Swissdec), the positions cannot be overwritten)
— Regelwerk SSK zur Online-Steuerdeklarationslösung für Juristische Personen, as at 31.03.2026
Two channels, and the data delivered is treated the same either way. The upload needs no contract with swissdec. Anyone who wants to build something today that arrives builds an artefact a human uploads, rather than waiting for a contractual basis that its own holder describes as still to be created.
To Treuhand firms. Three things converge from chapters 5 and 9, and they count operationally.
Where a general power of attorney is registered, the access codes go directly to the representative: «Beim Vorliegen einer registrierten, generellen Vollmacht wird das Schreiben an den Vertreter verschickt» (where a registered general power of attorney exists, the letter is sent to the representative) (Fragen und Antworten of the kantonales Steueramt Zürich, 08.09.2025), and «auch die künftigen Zugangscodes für die elektronische Deklaration werden diesem Vertreter zugestellt» (future access codes for the electronic declaration are also delivered to that representative) (Hilfe-Center article «Vertreter, Vollmacht, Formular» — representative, power of attorney, form). The client's own access credentials never change hands.
There is no role concept, and no record of changes visible to users: «ZHcorporateTax bietet kein Rollenmodell mit unterschiedlichen Berechtigungen an. Eine Steuererklärung kann geteilt werden, wobei alle Benutzer die gleichen Rechte haben» (ZHcorporateTax offers no role concept with differing permissions. A tax return can be shared, with all users holding the same rights), and on the question of who made a change: «Diese Informationen sind in der Datenbank teilweise vorhanden, sind aber für die Benutzenden in der Anwendung nicht ersichtlich» (this information is partly present in the database, but is not visible to users in the application) (both Q&A, 08.09.2025). An internal four-eyes check cannot be modelled inside the portal itself.
And anyone delivering the E-Bilanz electronically can no longer overwrite Aktiven, Passiven, and Erfolgsrechnung in the portal: under Grundsatz 6, the validation rules of the SSK Regelwerk for these three dialogues apply expressly to manually entered fields alone. The machine route is the less validated of the two. That is not a warning against it; it says where the check has to happen, which is before the upload.
The bottom line
In Switzerland, what decides the machine-readable Jahresrechnung is not the format but three gates that someone set and someone can open: a login that recognizes only natural persons, a contract that its own holder describes as still to be created, and a set of instructions that appears not once in 33'000 words of cantonal documentation.