Cryptocurrency license in Switzerland and comprehensive regulation overview in 2026

Disclaimer: This material is for general informational purposes only. It does not constitute legal, tax, or financial advice. Cryptocurrency licensing requirements depend on your specific business model and activities. Always consult with qualified legal and regulatory professionals before making decisions. Requirements may change — verify current regulations with FINMA or a licensed advisor.

Switzerland has established itself as a premier jurisdiction for cryptocurrency businesses. Clear regulatory frameworks, political stability, and an innovation-friendly approach make it attractive. This guide walks you through the complete licensing process. You'll learn how to select the right authorization type, register your company, and maintain ongoing compliance. Whether you're launching a crypto exchange, custody service, or DLT trading platform, understanding Switzerland's regulatory landscape is essential for legal operations and long-term success.

Switzerland offers four main authorization routes for cryptocurrency businesses. Each is designed for specific activities and capital requirements. The regulatory framework distinguishes between financial intermediaries handling client assets and companies providing technology services without custody functions.

Self-regulatory organization membership applies to financial intermediaries providing crypto exchange, custody, or payment services. Companies join a FINMA-recognized SRO (such as VQF or ARIF) to ensure AML compliance. They don't need direct FINMA supervision.

Requirements: Swiss legal entity (AG or GmbH), resident director with signing authority, local office, paid-in capital, Swiss-based AML department.

Timeline: 5–6 months with proper documentation. Application fee: 1,500–3,000 CHF. Annual membership: 1,500–2,500 CHF.

Sandbox vs. SRO distinction: The Swiss Banking Act sandbox allows companies to accept deposits up to CHF 1 million. Deposits must be non-interest-bearing with investor disclosure. Settlement accounts permit funds forwarded within 60 days. SRO membership governs AML supervision. It doesn't grant deposit-taking privileges beyond these specific exemptions.

The FinTech license suits companies accepting public deposits up to 100 million CHF. They cannot invest funds or pay interest. This authorization works for payment service providers and certain crypto platforms that don't engage in traditional banking activities.

Requirements: Swiss legal entity (AG, corporation, or GmbH), legal address and operations in Switzerland, minimum three directors, minimal share capital of 300,000 CHF with prudential and governance standards.

Cost: 100,000–250,000 CHF including government fees and professional services. Annual supervisory fee: 2,500–5,000 CHF.

Timeline: Preliminary assessment (1–2 months), documentation preparation, FINMA submission (1 month). Total process approximately 6–12 months.

This authorization applies to multilateral trading platforms for DLT securities. These are ledger-based securities per Art. 973d CO. FINMA grants this license under FinMIA Chapter 4a after audit firm verification.

Key features: Allows direct access for private individuals. Traditional trading facilities are restricted to qualified participants like banks. Includes custody, clearing, and settlement without additional licenses.

Example: BX Digital received Switzerland's first DLT Trading Facility license on March 12, 2025. It became effective May 14, 2025 as a small-scale facility for supervised participants.

Requirements: Swiss legal entity with registered office in Switzerland, comprehensive business plan, qualified board members, robust AML/KYC procedures, technical infrastructure documentation.

Full banking licenses suit crypto banks offering comprehensive services. These include deposits, lending, securities trading, and asset management. This route requires the highest capital and operational standards.

Capital requirements: Minimum capital typically 10 million+ CHF for full banking authorization. The most stringent prudential standards apply.

Services enabled: Client crypto asset custody, trading platform management, investment and asset-backed token issuance, deposit acceptance, payment operations and account opening.

Timeline: Application preparation (2 – 3 months) plus FINMA review (4 – 6 months). Total approximately 6 – 9 months.

Comparison table:

The licensing process follows five core stages. Each has specific requirements and timelines. Proper preparation reduces delays and increases approval probability.

Process overview:

1. Register Swiss company (AG or GmbH)
2. Prepare comprehensive documentation package
3. Establish local substance (office and personnel)
4. Submit application to SRO or FINMA
5. Receive authorization after review

Choosing legal form: AG vs. GmbH

AG (Aktiengesellschaft): Minimum capital 100,000 CHF (50,000 CHF paid at registration). Suitable for larger operations and future fundraising. Shares are freely transferable. Higher administrative requirements apply. Learn more about Opening a Swiss Corporation (AG).

GmbH (Gesellschaft mit beschränkter Haftung): Minimum capital 20,000 CHF (fully paid at registration). Appropriate for smaller operations. Ownership transfer requires notarization. Lower administrative burden. Explore Swiss GmbH Formation guide.

Both structures provide limited liability protection. AG offers more flexibility for capital markets access. GmbH suits closely held operations.

Capital requirements

GmbH: 20,000 CHF fully paid before registration.

AG: 100,000 CHF minimum. At least 50,000 CHF (50%) paid at registration. Remaining capital is callable.

Capital must be deposited in a Swiss bank account during formation. For crypto licenses, regulators expect full capital payment regardless of minimum requirements.

Canton selection for tax and business considerations

Zug: Corporate income tax (CIT) approximately 11.9%. Transparent crypto/blockchain legislation. Government services payable in Bitcoin/Ethereum. Established crypto ecosystem. Compare Cantons with the lowest taxes.

Zurich: Larger financial center. Extensive banking relationships. Slightly higher tax rates than Zug. Strong professional services infrastructure.

Geneva: International presence. French-speaking. Access to private banking sector. Competitive tax rates.

Federal CIT: 7.83% effective rate on pre-tax profit. Cantonal rates add 4 – 13%. Total CIT ranges from 11.9 – 21% depending on location. Understand Corporate Taxes in Switzerland.

Business plan and financial projections

FINMA and SROs require detailed business plans. They must demonstrate viability and risk management. Essential components:

• Business model description (revenue sources, target markets, competitive positioning)
• Three-year financial projections (income statements, balance sheets, cash flow)
• Risk analysis covering operational, market, liquidity, and regulatory risks
• Risk mitigation strategies and contingency planning

Financial projections must be realistic. Support them with market research. Overly optimistic forecasts raise red flags with regulators.

Internal policies development (AML/KYC, risk management)

AML/KYC policy requirements:

• Customer identification procedures (KYC standards)
• Transaction monitoring systems and thresholds
• Suspicious activity reporting (SAR) protocols
• Compliance officer appointment (Swiss resident)
• Enhanced due diligence for high-risk clients
• Record retention procedures (minimum 10 years)

Learn about Travel rule for virtual assets.

Risk management policy components:

• Risk assessment framework based on business activities
• Internal control systems and segregation of duties
• Conflict of interest management
• Cybersecurity measures (two-factor authentication, DDoS protection)
• Business continuity and disaster recovery planning

Goldblum and Partners assisted a blockchain gaming company in developing comprehensive AML/KYC frameworks. We obtained FINMA classification for their token structure. The engagement included regulatory analysis, ICO licensing requirements, and integration of financial crime prevention protocols throughout the development process.

Documents for directors and beneficial owners

Required documentation:

• Passport copies (notarized) for all directors, shareholders, and ultimate beneficial owners (UBOs)
• Criminal record certificates (original, not older than 6 months)
• Detailed CVs with education and professional experience
• Proof of residence (utility bills within 3 months)
• Bank statements for each director and shareholder
• Source of funds documentation for capital contributions
• Professional references (two per person)

Directors must demonstrate relevant financial or blockchain industry experience. Typically 3+ years required. No criminal convictions related to financial crimes.

Physical office rental

Swiss crypto companies must maintain a genuine physical presence. Virtual offices and mailbox addresses do not satisfy substance requirements.

Office requirements:

• Lease agreement for commercial space in Switzerland
• Functional workspace (not just registered address)
• Located in canton where company is registered
• Sufficient for planned operations and staff

Popular locations: Zug (Crypto Valley), Zurich (financial center), Geneva (international presence).

Hire qualified personnel (resident director, AML officer)

Mandatory personnel:

Swiss resident director: At least one director must be Swiss resident with individual signing authority. This person cannot be a legal entity. They must actively participate in management. Review Swiss Resident Director requirements.

AML compliance officer: Swiss-based professional responsible for AML/KYC implementation. Must have knowledge of Swiss and international AML regulations. Requires regular training. Ensures policy updates.

Qualifications: Higher education in finance, law, or management. 3+ years experience in financial services or blockchain sector. Confirmed professional references. No criminal record.

For our client establishing an asset management company, we handled complete regulatory setup. This included appointment of a Swiss-based director and AML officer. We secured registered address and structured governance framework to meet AML and corporate control obligations. The engagement facilitated smooth market entry with optimized operational setup.

Application process and regulator communication

SRO route (VQF example):

1. Submit membership application with complete documentation
2. SRO conducts preliminary review (2–4 weeks)
3. Request for clarifications or additional documents
4. SRO approval and membership confirmation
5. Annual internal AML audits and potential spot checks

FINMA direct route:

1. Pre-application consultation (optional but recommended)
2. Formal application submission with full documentation
3. FINMA formal completeness check (2–4 weeks)
4. Substantive review and assessment (4–6 months)
5. Requests for additional information or clarifications
6. License issuance (1–2 months after final approval)

Maintain proactive communication with regulators. Respond promptly to information requests. Delays often result from incomplete or unclear documentation rather than regulatory processing.

Expected timeline

SRO membership: 5 - 6 months with proper documentation preparation.

FINMA FinTech license: 6 - 12 months total (1 - 3 months preparation, 4 - 6 months review, 1 - 2 months finalization).

FINMA banking license: 6 - 9 months (2 - 3 months preparation, 4 - 6 months review).

Timeline varies based on business model complexity, documentation quality, and responsiveness to regulator inquiries. Complex activities (asset management, custody services) require longer review periods.

Understanding the complete cost structure helps with accurate budgeting. It prevents surprises during the licensing process.

Additional ongoing costs:

• Office rental: 2,000–8,000 CHF/month depending on location
• Director salary: 80,000–150,000 CHF/year
• AML officer salary: 70,000–120,000 CHF/year
• Annual audit: 5,000–15,000 CHF
• Government supervisory fees: 2,500–5,000 CHF/year

For FINMA direct licensing (FinTech or banking), add 100,000–250,000 CHF for application preparation and regulatory fees.

Swiss crypto companies operating as financial intermediaries must comply with the Anti-Money Laundering Act (AMLA). Requirements apply regardless of whether authorization comes through SRO membership or direct FINMA licensing.

Core AML obligations:

Customer identification (KYC): Verify identity for all clients. Collect and verify identity documents, proof of address, beneficial ownership information for legal entities.

Transaction monitoring: Monitor all crypto transfers. Collect originator and beneficiary data including wallet verification.

Suspicious activity reporting: Report suspicious activities to Money Laundering Reporting Office Switzerland (MROS). Maintain detailed records of all transactions and customer due diligence. Implement automated monitoring systems for unusual patterns.

Enhanced due diligence: Apply heightened scrutiny for politically exposed persons (PEPs), high-risk jurisdictions, large transactions, complex ownership structures.

Record retention: Maintain all customer identification and transaction records for minimum 10 years after relationship termination.

Official AMLA text (English): Federal Act on Combating Money Laundering and Terrorist Financing

DLT regulation (Distributed Ledger Technology Act)

Switzerland's DLT Act (effective August 1, 2021) adapted 10 federal laws. It created legal certainty for tokenized assets and blockchain-based financial services.

Key innovations:

Uncertificated ledger-based securities: New category allowing registration of securities in blockchain registries. Provides equivalent protection to traditional transferable securities. Enables tokenization of financial instruments without physical certificates.

DLT Trading Facility license: Dedicated authorization for multilateral trading of security tokens on blockchain systems. Requires FINMA licensing with mandatory AML compliance and client protection measures.

Bankruptcy protection: Clarified treatment of crypto assets in insolvency proceedings. Digital assets held in DLT systems receive specific legal treatment for segregation and recovery.

Legal certainty for transfers: Established clear rules for transfer of rights recorded in distributed ledgers. Reduced legal uncertainty around ownership and transfer of tokenized assets.

The DLT framework positions Switzerland as a jurisdiction with comprehensive legal infrastructure for blockchain-based financial services. This distinguishes it from jurisdictions with fragmented or unclear regulations.

The Swiss Financial Market Supervisory Authority (FINMA) serves as the primary regulator for crypto businesses. It oversees those handling client assets or providing financial services.

FINMA's regulatory approach:

Technology-neutral supervision: FINMA applies functional regulation based on economic substance rather than technology type. Blockchain-based services receive equivalent treatment to traditional financial services performing similar functions.

Authorization types: FINMA provides five permission types with varying supervision intensity. These include licensing, recognition, authorization, approval, and registration. Crypto businesses typically require licensing (for banks, securities dealers) or recognition (for SROs).

Risk-based assessment: FINMA evaluates each application based on business model, capital adequacy, governance structure, risk management systems, and AML/KYC procedures. No standardized approval process exists. Each case receives individual assessment.

Ongoing supervision: Licensed entities face regular audits, reporting requirements, and compliance reviews. FINMA can impose sanctions, restrict activities, or revoke licenses for non-compliance.

Learn more about FINMA: The Swiss Financial Regulator.

Self-regulatory organizations provide an alternative supervision route for financial intermediaries. This includes crypto service providers. FINMA officially recognizes SROs as authorized supervisory bodies under AMLA.

SRO functions:

Membership authorization: Accept applications for membership. Review documentation. Verify compliance with AML/KYC standards. Members can operate as financial intermediaries without direct FINMA supervision.

Ongoing monitoring: Conduct regular audits of member companies (typically annual internal AML audits). Perform spot checks and investigations when necessary.

Enforcement: Issue sanctions for non-compliance. These range from warnings to membership termination. Report serious violations to FINMA and MROS.

Guidance and support: Provide members with regulatory updates, compliance guidance, and best practice recommendations.

Major Swiss SROs for crypto:

VQF (Verein zur Qualitätssicherung von Finanzdienstleistungen): Largest SRO for financial intermediaries including crypto companies. Recognized by FINMA for AML supervision.

ARIF (Association Romande des Intermédiaires Financiers): French-speaking Switzerland's primary SRO for financial intermediaries.

Regulatory hierarchy:

SRO membership offers a more accessible and cost-effective route. It's designed for companies not requiring full banking licenses. It maintains regulatory compliance and market credibility.

FINMA maintains public registries of authorized financial institutions and recognized SROs. These registries allow verification of licensed entities and regulatory status.

Key registries:

• Licensed institutions: Banks, securities dealers, insurance companies, and other directly supervised entities
• Recognized SROs: List of FINMA-approved self-regulatory organizations</li>
• FinTech license holders: Companies authorized under simplified FinTech regime</li>

Access registries at: FINMA official website

Several Swiss banks actively serve cryptocurrency businesses. Account opening remains selective and requires substantial documentation.

Banks serving crypto companies:

Sygnum Bank: First Swiss bank to receive FINMA banking and securities dealer licenses for digital assets (August 2019). Provides custody, trading, tokenization, and banking services. Serves institutional clients and other banks through B2B platform.

SEBA Bank: FINMA-licensed crypto bank (August 2019) offering integrated crypto and traditional banking services. Provides custody, trading, asset management, and corporate banking for crypto businesses.

Swissquote: Established online bank offering crypto trading and custody for retail and corporate clients. Integrated crypto services with traditional banking platform.

PostFinance: Swiss Post's financial services arm partnered with Sygnum to offer Bitcoin and Ethereum trading/custody to 2.5 million clients (2023).

Zürcher Kantonalbank (ZKB): Fourth-largest Swiss bank by assets (235 billion CHF). Launched Bitcoin and Ethereum trading for Swiss residents (2024).

Account opening requirements:

• Complete business documentation and licenses
• Detailed explanation of business model and transaction flows
• Source of funds verification for capital
• AML/KYC procedures documentation
• Local substance evidence (office, personnel)
• Realistic transaction volume projections

Explore Swiss bank account overview.

When assisting clients with Swiss market entry, we coordinate banking relationships alongside company formation and licensing. Our established connections with cantonal and private banks help navigate the stringent onboarding requirements. These often challenge international crypto businesses.

The European Union's Markets in Crypto-Assets (MiCA) regulation establishes unified rules for crypto service providers across EU member states. Switzerland, as a non-EU country, maintains independent regulatory frameworks.

Regulatory structure comparison:

Switzerland: Risk-oriented approach through FINMA and SROs with case-by-case business model assessment. Functional regulation focuses on economic substance rather than technology. Flexible framework accommodates innovation while maintaining strict AML/KYC standards.

MiCA: Unified classification of tokens (utility, asset-referenced, e-money, security) with standardized requirements for all EEA participants. Single rulebook approach reduces regulatory fragmentation across EU member states.

Licensing differences:

Swiss licenses: National scope requiring separate authorization for each jurisdiction. VASP license from FINMA or SRO membership allows operations within Switzerland.

MiCA CASP license: Single authorization valid across entire EU/EEA without additional national licenses. Crypto Asset Service Provider (CASP) license enables passporting rights to all member states.

Capital requirements:

Switzerland: From 100,000 CHF depending on activities and structure.

MiCA: From 125,000 EUR for most CASP categories.

Advantages of Swiss approach:

• Flexibility for innovative services and asset tokenization
• Established regulatory precedents and case law
• Strict but adaptable AML/KYC framework
• Political stability and regulatory predictability
• Access to sophisticated banking infrastructure

MiCA advantages:

• Single license for entire EU market access
• Unified supervision through ESMA coordination
• Predictable regulatory requirements across jurisdictions
• Reduced compliance costs for multi-country operations

Important consideration: MiCA applies to crypto platforms serving EU clients regardless of company location. Swiss companies targeting EU markets must comply with MiCA requirements separately from Swiss licensing.

Corporate taxation for crypto businesses

Federal corporate income tax: 7.83% effective rate on pre-tax profit (8.5% on after-tax profit, tax-deductible). No federal capital tax.

Total corporate tax burden: 11.9–21% on pre-tax profit depending on canton and municipality. Progressive rates apply in some locations.

Crypto operations treatment: Trading, services, and mining income included in regular commercial income without special tax provisions. No separate crypto-specific tax regime.

Example (Zug): Total CIT approximately 11.9% combining federal and cantonal rates. Transparent legislation allows government service payments in Bitcoin/Ethereum.

Individual taxation for crypto holders

Wealth tax: Swiss tax residents declare crypto holdings as assets subject to cantonal wealth tax. Rates range from 0.1–1% depending on canton (2026).

Capital gains exemption: Private investors holding crypto as personal assets face no capital gains tax on sales. Exemption applies when crypto is not classified as business asset or professional trading activity.

Professional traders: Individuals classified as professional traders pay income tax on crypto gains. Federal rate is 7.83% plus cantonal 6–12% rates. Classification depends on trading frequency, holding periods, and leverage use.

VAT treatment: No VAT on crypto trading for individuals. Cryptocurrency treated as non-taxable currency equivalent.

Tax reporting from 2026: Switzerland implements OECD's Crypto-Asset Reporting Framework (CARF). This requires crypto exchanges, banks, and brokers to collect client wallet data, balances, and transaction information. Data exchange with 74 partner jurisdictions begins in 2027.

Many applicants focus on initial licensing fees. They overlook substantial ongoing operational expenses.

Hidden costs:

• Office rental in prime Swiss locations (2,000 – 8,000 CHF/month)
• Qualified personnel salaries (director 80,000 – 150,000 CHF/year, AML officer 70,000 – 120,000 CHF/year)
• Annual audits and compliance reviews (5,000 – 15,000 CHF)
• Technology infrastructure and cybersecurity systems
• Professional liability insurance

Solution: Prepare comprehensive three-year budget including all operational costs. Factor in salary increases, office expansion, and additional compliance requirements as business scales.

FINMA and SROs reject applications with insufficient business planning or unrealistic financial projections.

Common deficiencies:

• Vague revenue models without market validation
• Overly optimistic growth projections
• Inadequate risk analysis
• Missing competitive analysis
• Unclear target market definition

Solution: Develop detailed business plan with conservative financial projections supported by market research. Include comprehensive risk assessment covering operational, market, liquidity, and regulatory risks with specific mitigation strategies.

Incomplete or generic AML/KYC policies lead to automatic application rejection or extended review periods.

Documentation gaps:

• Template policies without customization to business model
• Missing transaction monitoring procedures
• Unclear suspicious activity reporting protocols
• No evidence of system implementation or testing
• Insufficient staff training documentation

Solution: Develop comprehensive, business-specific AML/KYC policies with documented implementation procedures. Include transaction monitoring thresholds, customer risk classification methodology, and detailed SAR protocols. Demonstrate system functionality through testing documentation.

Regulators require qualified, experienced directors and compliance officers with Swiss residency.

Qualification issues:

• Directors without relevant financial services experience
• AML officers lacking proper training or certifications
• Non-resident directors without proper authorization
• Management team with insufficient blockchain/crypto knowledge

Solution: Appoint Swiss-resident director with minimum 3 years financial services or blockchain experience. Hire qualified AML officer with knowledge of Swiss and international AML regulations. Ensure all key personnel have clean criminal records and professional references.

For a Ukrainian IT company developing AI solutions, we provided comprehensive legal support for business process reorganization valued at 200 million EUR. The engagement included consultations on corporate structuring, merger conditions, subsidiary organization, tax optimization, and risk management during cross-border migration. This resulted in successful implementation and preparation of all necessary regulatory documentation.

Goldblum and Partners provides comprehensive legal support for cryptocurrency licensing in Switzerland. We combine regulatory expertise with practical business understanding.

Our advantages:

Specialized experience: Over 15 years supporting fintech and crypto companies through Swiss regulatory processes. Recognized by IFLR1000 (2020–2024) in Corporate/M&A and Restructuring categories. Ranked as "Recommended Firm" by ITR World Tax 2026.

Complete service package: End-to-end support from company formation through license acquisition and ongoing compliance. Single point of contact for all legal, regulatory, and corporate matters.

Established relationships: Direct connections with FINMA, major SROs (VQF, ARIF), and crypto-friendly banks. We facilitate introductions and coordinate multi-party processes.

Transparent pricing: Fixed-fee packages for standard services with clear scope definition. No hidden costs or surprise invoices. Free 15-minute initial consultation to assess requirements.

Multilingual team: Services in English, German, and Russian. International client experience across EU, UK, USA, Asia, and CIS countries.

Recent client outcomes:

• Assisted blockchain gaming company with FINMA token classification and ICO licensing (comprehensive regulatory analysis and compliance integration)
• Supported asset management company through SRO membership process including Swiss director appointment and AML officer placement (60 million EUR deal value)
• Advised Chinese biotech company on subsidiary registration and Series C+ funding securing over 100 million RMB

Response guarantee: We respond to all client inquiries within one hour during business hours (9:30–17:30 CET). Proactive communication throughout licensing process with regular status updates.

Switzerland's cryptocurrency regulatory framework combines clarity, stability, and innovation-friendly policies. This makes it a premier jurisdiction for serious crypto businesses. The licensing process requires substantial preparation, qualified local presence, and comprehensive compliance systems. However, it provides long-term benefits through regulatory certainty and access to sophisticated financial infrastructure.

Key takeaways:

• Four main authorization routes (SRO membership, FinTech license, DLT Trading Facility, banking license) suit different business models
• Timeline: 5 – 6 months for SRO membership, 6 – 12 months for FINMA licensing
• Costs: 15,000–25,000 CHF for SRO route, 100,000–250,000 CHF for FINMA direct licensing
• Mandatory requirements: Swiss company, resident director, local office, AML officer, comprehensive documentation
• Ongoing obligations: Annual audits, AML compliance, CARF reporting from 2026

Next steps:

1. Assess which authorization type suits your business model
2. Prepare preliminary business plan and financial projections
3. Identify suitable canton for company registration
4. Schedule consultation to review requirements and timeline

Start a cryptocurrency company in Switzerland or explore Swiss company formation guide.

Contact Goldblum and Partners for a free 15-minute consultation. Discuss your specific situation and receive tailored guidance on the optimal licensing path for your cryptocurrency business in Switzerland.