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Knowledgebase

Initial Coin Offering in Switzerland

Alex Buri, Off-Counsel
03.07.2025

Table of Contents

ICO Registration in Switzerland in 2025: Legal Framework and Regulatory Guide

In recent years, Switzerland has solidified its reputation as one of the most favorable jurisdictions for cryptocurrency projects, particularly those involving initial coin offerings (ICOs). Thanks to its forward-thinking regulatory approach, technological infrastructure, and stable legal environment, Switzerland continues to attract blockchain startups, investors, and developers.

As of 2025, launching an ICO in Switzerland is still considered one of the most efficient and secure ways to raise capital for blockchain-based projects. Companies looking to attract international investors may also consider offering incentives such as the Swiss Passport to enhance credibility and establish trust. The Swiss Financial Market Supervisory Authority (FINMA) plays a central role in regulating ICOs to ensure compliance with anti-money laundering laws, securities regulations, and investor protection rules.

This guide provides a comprehensive overview of how ICOs are registered and regulated in Switzerland in 2025, including token classification, the legal status of crypto assets, and the advantages of launching a project in Switzerland.

Understanding ICOs and Token-Based Fundraising

An ICO (Initial Coin Offering) is a method of raising funds by issuing digital tokens on a blockchain. These tokens are offered to investors in exchange for fiat currency or other cryptocurrencies (such as Bitcoin or Ethereum).

Unlike traditional venture capital or IPO routes, ICOs offer startups a decentralized, direct-to-investor funding mechanism. Depending on the structure, tokens may grant access to a product (utility), represent ownership rights (equity), or function as financial instruments (securities).

For larger projects involving substantial asset management, forming an AG Company can provide the necessary legal structure and shareholder protection. Switzerland’s legal system distinguishes clearly between these token types, which is why a proper legal classification of the token is a mandatory step in the registration process.
FINMA’s Approach to ICO Regulation

FINMA’s Approach to ICO Regulation


The Swiss regulator, FINMA, has issued official guidelines on how ICOs should be handled, and it continues to update them to keep pace with global and technological developments. As of 2025, FINMA focuses on a principle-based, technology-neutral approach, meaning that:
  • Blockchain technology is not regulated per se
  • Activities involving tokens are regulated based on their economic function and purpose
  • The existing financial market laws apply to token issuers if the token meets specific criteria (e.g., if it qualifies as a security or payment instrument). For entities handling digital assets, ensuring ongoing FINMA Supervision is critical to maintain regulatory compliance and investor confidence.

FINMA’s role includes:

  • Reviewing ICO documentation (whitepapers, terms and conditions)
  • Assessing token characteristics to determine if the issuer needs a license (e.g., securities dealer, bank, collective investment scheme)
  • Providing legal certainty through no-action letters or rulings

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Token Classification Under FINMA Guidelines

FINMA distinguishes three main categories of tokens, although hybrid tokens are increasingly common:
  • Payment Tokens
    Used as means of payment for acquiring goods or services. These are not classified as securities but are subject to anti-money laundering (AML) laws.
  • Utility Tokens
    Provide access to a digital application or service via a blockchain-based infrastructure. If the token has no investment characteristics, it is not considered a security.
  • Asset Tokens
    Represent assets such as equity, debt, or real estate. These are often classified as securities under Swiss law and are subject to licensing and prospectus requirements.
Hybrid tokens combine features of two or more types and must be evaluated carefully by legal advisors.

Preliminary Legal Review and ICO Planning

Before launching an ICO in Switzerland, project founders should conduct a legal review of their business model and token structure. This is typically done with the help of Swiss law firms or corporate advisory services.

Key preparatory steps include:
  • Drafting a compliant whitepaper with technical and legal disclosures
  • Preparing terms and conditions in line with Swiss contract and financial law
  • Identifying whether the ICO will be public or private, and whether it targets Swiss or international investors
  • Assessing whether the issuing company will require licensing (e.g., if acting as a financial intermediary)
These elements will form the basis for contacting FINMA and requesting a legal opinion or no-action letter.

Adam Abdellaoui

Of Counsel
+41 (44) 5152530
ICO Registration Process in Switzerland

ICO Registration Process in Switzerland

The ICO registration process in 2025 involves the following steps:
  • Company Formation
    Most projects choose to register a company in Zug, the heart of Crypto Valley. The typical legal forms include AG (joint stock company) or GmbH (limited liability company).
  • Whitepaper and Legal Documents
    Finalize all legal, technical, and business documentation, including data privacy statements, investor disclaimers, and risk factors.
  • AML Compliance
    Register with a Self-Regulatory Organization (SRO) and implement a KYC/AML process if tokens can be considered payment instruments or involve fiat conversion.
  • FINMA Notification or Inquiry
    Submit a request for a non-action letter or formal classification. If the ICO is deemed not to involve regulated activity, the project can proceed without a license. Managing funds during the ICO process may also require coordination with the Banking Sector to facilitate secure transactions and escrow services.
  • Token Sale and Distribution
    Launch the ICO publicly or privately, using smart contracts to manage token issuance and funds collection.

Advantages of Launching an ICO in Switzerland in 2025

Switzerland continues to offer a unique combination of regulatory clarity, technical infrastructure, and international credibility — making it one of the world’s most attractive jurisdictions for ICOs.

Key benefits include:
  • Legal Stability and Regulatory Transparency
    Switzerland’s regulatory authorities, especially FINMA, have provided one of the clearest legal frameworks for ICOs globally. Founders benefit from legal certainty, predictable enforcement, and access to professional compliance services.
  • Crypto-Friendly Ecosystem
    With years of experience regulating blockchain activity, Swiss cantons such as Zug, Geneva, and Zurich have cultivated ecosystems that support crypto entrepreneurs. From lawyers to tax specialists and blockchain developers, service providers are readily available.
  • Strong Banking and Financial Infrastructure
    Though traditional banks remain cautious, several crypto-friendly banks now operate in Switzerland, offering corporate accounts for ICO projects. This access to financial services improves project credibility and investor trust.
  • Tax Optimization
    Swiss tax law allows favorable treatment for companies operating in the innovation and tech sectors. With proper structuring, ICO income and capital gains can be taxed efficiently, especially in business-friendly cantons like Zug or Lucerne.
  • International Access
    Switzerland is not an EU member, but it maintains bilateral agreements that allow market access across Europe. For global blockchain companies, this provides a bridge between EU and non-EU jurisdictions.
  • Reputation and Investor Trust
    Swiss-registered ICOs carry a high level of credibility due to the country's reputation for regulatory compliance, neutrality, and political stability. This can make a significant difference when approaching institutional or foreign investors.
Zug and Crypto Valley in 2025

Zug and Crypto Valley in 2025

Known as Crypto Valley, the canton of Zug has established itself as the epicenter of blockchain innovation in Europe. It hosts a dense cluster of startups, exchanges, legal firms, and foundations working on blockchain, DeFi, NFTs, and Web3 technologies.

Why Zug remains a top choice in 2025:
  • Business-friendly tax regime
  • Availability of qualified service providers
  • Local government support for blockchain projects
  • Access to Swiss and EU investors
  • Proximity to Zurich, a financial and tech hub
Many projects launch their ICOs through AG companies based in Zug, benefiting from a high level of professionalism, English-speaking infrastructure, and crypto-native culture. For projects involving asset management or trustee services, adherence to the FinIA Act is mandatory to secure proper licensing and operational clearance.
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Post-ICO Obligations and Legal Compliance

Post-ICO Obligations and Legal Compliance

After completing the ICO, companies must fulfill several legal obligations:
  • Ongoing AML and KYC compliance
  • Data protection in line with the revised Swiss Data Protection Act (DPA) and GDPR for EU-targeting projects
  • Corporate accounting and audit according to the Swiss Code of Obligations
  • Reporting to FINMA, if the business activities evolve into regulated financial services (e.g., custody, exchange, asset management)
Some projects also migrate toward becoming regulated financial institutions (e.g., fintech banks, investment funds, or collective asset managers).

Conclusion: Is Switzerland Still the Best Place for ICOs?

In 2025, Switzerland maintains its leadership as a hub for blockchain fundraising. While the global ICO market has matured, the country continues to offer unmatched clarity, compliance pathways, and access to both capital and innovation talent.

For teams seeking to launch an ICO in a legally secure and internationally recognized jurisdiction, Switzerland — and especially the Crypto Valley of Zug — remains a top-tier choice.

Working with experienced Swiss advisors ensures full legal alignment, tax efficiency, and operational readiness. Whether your project involves DeFi, tokenization, or blockchain infrastructure, the Swiss ecosystem offers tools, trust, and transparency.

To begin your ICO journey in Switzerland, reach out to professional company formation consultants who can assist with legal structuring, regulatory filings, and post-launch compliance.

Adam Abdellaoui

Of Counsel
+41 (44) 5152530

FAQ – ICO Registration in Switzerland

Yes, ICOs are legal in Switzerland and regulated by the Swiss Financial Market Supervisory Authority (FINMA) based on the token's function and economic purpose.