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Wissensdatenbank

Financial Services Licence Switzerland: FINMA, SRO, and Crypto Authorisation Guide

Marcus Altenburg, Managing Partner
9 March, 2026
By Marcus Altenburg, Managing Partner at Goldblum and Partners AG — advising on Swiss financial regulation since 2012.

Obtaining a financial services licence in Switzerland requires navigating a layered regulatory system: direct FINMA licences for banks, securities firms, and insurers; FinIA licences supervised by Supervisory Organisations for portfolio managers and trustees; and SRO membership for financial intermediaries under the Anti-Money Laundering Act. This guide covers every authorisation path — from the FINMA sandbox to a full banking licence — with current requirements, costs, and timelines as of March 2026.

What Is the Swiss Financial Regulation Framework?

Swiss financial regulation rests on six principal statutes. Each governs a specific layer of the financial intermediary licence system, and understanding which law applies is the first step in determining the correct authorisation path.
Two additional pieces of legislation are relevant for blockchain and crypto businesses:

DLT Act (in force since August 2021): Amended the Banking Act, CISA, and the Debt Enforcement and Bankruptcy Act (SchKG) to introduce DLT trading facility licences and bankruptcy segregation for crypto assets (Art. 242a SchKG).
Financial Market Infrastructure Act (FMIA / FinfraG): Governs exchanges, trading venues, central counterparties, trade repositories, and payment systems.

FINMA (Swiss Financial Market Supervisory Authority) administers all of these statutes. It issues licences, recognises SROs, authorises Supervisory Organisations, and enforces compliance.

Who Needs a Financial Services Licence in Switzerland?

The correct authorisation path depends on what your business does, not what it calls itself.

Does your business accept public deposits?
  • Yes, up to CHF 1 million → No licence required (FINMA sandbox), but disclosure obligations apply
  • Yes, up to CHF 100 million, no investment or interest → Fintech licence (Art. 1b Banking Act)
  • Yes, above CHF 100 million or with investment/interest → Full banking licence

Does your business manage client assets under a power of attorney?
  • On a commercial basis (> CHF 5 million AuM, > 20 clients, or > CHF 50,000 annual revenue) → FinIA portfolio manager licence + SO membership

Does your business manage trust assets?
  • On a commercial basis (same thresholds) → FinIA trustee licence + SO membership

Does your business operate a trading venue for DLT securities?
  • Yes → DLT trading facility licence from FINMA

Does your business provide financial intermediary services (currency exchange, crypto brokerage, payment processing, lending, custody without banking features)?
  • Yes → Financial intermediary licence via SRO membership under AMLA

Does your business manage collective investment schemes?
  • Yes → Fund management company licence or manager of collective assets licence from FINMA

Does your business provide insurance services?
  • Yes → FINMA insurance licence

If your business holds a direct FINMA licence (bank, securities firm, insurance company), AML compliance is supervised directly by FINMA — separate SRO membership is not required.

Direct FINMA Licences

FINMA grants five forms of statutory authorisation, each with different supervisory intensity:

Banks

A banking licence is required for any entity that accepts deposits from the public on a professional basis. FINMA presumes professional status at 20 or more depositors. Minimum capital: CHF 10 million. The application process typically takes 6–12 months and requires comprehensive documentation of governance, risk management, capital adequacy, and AML compliance. Legal basis: Banking Act (BankG).

Securities Firms

Securities firms include broker-dealers, market makers, issuing houses, and operators of organised trading facilities (OTFs). Minimum capital depends on the activity type and ranges from CHF 1.5 million to CHF 5 million. Since 2020, securities firms are licensed under FinIA (Art. 41 ff.) rather than the former Stock Exchange Act. Legal basis: FinIA Art. 41–59.

Insurance Companies

All insurers operating in Switzerland — life, non-life, and reinsurers — require a FINMA licence. Insurance intermediaries must register with FINMA but do not need a full licence. Goldblum does not advise on insurance licensing; this section is included for completeness.

Fund Management Companies and Managers of Collective Assets

Fund management companies (Art. 32 ff. FinIA) manage Swiss collective investment schemes. Managers of collective assets (Art. 24 ff. FinIA) manage assets for collective investment schemes, pension funds, or occupational benefit institutions above certain thresholds. Both require FINMA licences with minimum capital starting at CHF 1 million (fund management) or CHF 200,000 (managers of collective assets). Legal basis: FinIA and CISA.

Financial Market Infrastructures

Exchanges, multilateral trading facilities, central counterparties, central securities depositories, trade repositories, and payment systems are licensed under FMIA. These are large-scale institutional licences with capital requirements starting at CHF 1 million for smaller infrastructure types. Legal basis: FMIA (FinfraG).

How Do Portfolio Managers and Trustees Get Licensed Under FinIA?

The Financial Institutions Act (FinIA), in force since 1 January 2020, introduced mandatory licensing for portfolio managers and trustees. Before FinIA, these professionals required only SRO membership for AML purposes. Now they need a FINMA licence and ongoing supervision by a Supervisory Organisation (SO).

Portfolio Managers

A portfolio manager is a person who manages client assets under a power of attorney on a commercial basis. Commercial basis is presumed when any one of these thresholds is met:

  • Gross annual revenue from portfolio management exceeds CHF 50,000
  • More than 20 ongoing client relationships maintained per calendar year
  • Assets under management exceed CHF 5 million at any time

Requirements:
  • Minimum capital: CHF 100,000, fully paid in cash and maintained continuously
  • Capital adequacy: 25% of fixed costs (capped at CHF 10 million)
  • Professional indemnity insurance (up to 50% can count toward qualifying capital)
  • At least two qualified managers with minimum 5 years of relevant professional experience and 40 hours of training
  • Adequate risk management and internal control systems
  • Swiss domicile and commercial register entry
  • Affiliation with a licensed SO before applying to FINMA

Trustees

Under Art. 17 para. 2 FinIA, a trustee is a person who commercially manages or holds a separate fund for beneficiaries based on a trust instrument within the meaning of the Hague Convention of 1 July 1985.

Switzerland does not have domestic trust law — Swiss trusts do not exist. However, Swiss-based trustees who manage foreign trusts (typically governed by English, Jersey, or Cayman Islands law) must hold a FinIA licence if they operate on a commercial basis. The same thresholds apply as for portfolio managers.

Key distinction from portfolio managers:
  • A trustee legally owns the trust assets; a portfolio manager does not own client assets
  • Trust management is generally not a financial service under FinSA, so trustees do not need an ombudsman affiliation
  • If a person acts as both trustee and portfolio manager, two separate licences are required

FINMA Guidance 01/2024 clarified that the CHF 5 million threshold applies to trustees. Trustees newly caught by this clarification had until end of 2024 to submit licence applications.

Exemptions from Licensing

No FinIA licence is required for trustees serving exclusively:
  • Persons connected by family ties (direct bloodline, up to fourth-degree collateral relatives, spouses, registered partners, co-heirs)
  • Entities with economic ties (group companies, pension funds, charitable foundations)
  • Private trust companies (PTCs) established for single trusts or same-settlor/beneficiary-group trusts
  • Dedicated trust companies (DTCs) acting exclusively for trusts established by the same person or family, held and monitored by a FinIA-licensed institution

The Five Supervisory Organisations (SOs)

Portfolio managers and trustees are licensed by FINMA but supervised day-to-day by an SO. FINMA granted the first SO licences on 6 July 2020. All five currently licensed SOs:
Switching between SOs is permitted only at year-end, with change requests due to FINMA by 15 November.

Licensing Status (March 2025 FINMA Data)

FINMA received 1,864 total applications for portfolio manager and trustee licences since 2020. Of these, 1,532 (82%) were approved, 131 withdrawn, and approximately 200 remained pending. In over 40% of cases, FINMA requested amendments at least five times before granting the licence.

SRO Membership: The Financial Intermediary Licence Path

Financial intermediaries who do not hold a direct FINMA licence must obtain a financial intermediary licence by joining a Self-Regulatory Organisation (SRO) under AMLA Art. 14. An SRO supervises its members' compliance with anti-money laundering and counter-terrorism financing obligations.

Who Needs SRO Membership

SRO membership is the correct path for businesses that conduct any of the following on a commercial basis:

  • Currency exchange (fiat and cryptocurrency on/off ramp)
  • Payment processing and remittance
  • Crypto custody with individual wallets (without banking features)
  • Crypto brokerage and wealth management
  • ICO and token issuance
  • Precious metals dealing
  • Lending operations
  • Fiduciary activities (that do not trigger FinIA licensing)

The 11 Recognised SROs

FINMA recognises 11 SROs. Three are "general" SROs open to any financial intermediary; the remainder serve specific sectors:

General SROs (open to all):
Sector-specific SROs:

SRO Application Process

Step 1: Establish a Swiss company. An AG (minimum share capital CHF 100,000, at least 50% paid in) or GmbH (CHF 20,000, fully paid in). At least one director must be resident in Switzerland (Art. 718a CO for AG, Art. 814 CO for GmbH). Our Swiss company formation team handles the entire incorporation process through commercial register entry.

Step 2: Prepare compliance documentation. Business plan, AML/KYC internal directives, risk assessment matrix, organisational chart with clear responsibilities, and identification of beneficial owners.

Step 3: Choose an SRO and submit application. For most crypto and fintech businesses, VQF membership or PolyReg are the standard choices. VQF is the largest and most established; PolyReg has strong crypto-sector expertise. Goldblum and Partners advises on the optimal SRO selection for your business model.

Step 4: SRO audit. The SRO reviews your AML policies, data storage procedures, risk management framework, and staff qualifications.

Step 5: Membership confirmation. Timeline: 2–3 months for complete applications with professional documentation.

SRO vs SO: Key Differences

SROs and Supervisory Organisations serve different purposes under different laws:

How to Get a Crypto Licence in Switzerland

Switzerland does not issue a standalone "crypto licence Switzerland" category. Instead, crypto businesses are regulated through the existing financial law framework based on what activities they perform. FINMA classifies tokens into three categories, and the classification determines which rules apply:

Which Path for Your Crypto Business

For a step-by-step guide on starting a cryptocurrency company in Switzerland, including entity selection and bank account opening, see our dedicated guide.

DLT Trading Facility Licence

Introduced by the DLT Act in August 2021, this licence allows platforms to trade DLT securities (tokenised assets on a distributed ledger) and optionally provide custody, clearing, and settlement services.

FINMA issued the first DLT trading facility licence to BX Digital AG (part of the Börse Stuttgart Group) in March 2025. BX Digital uses the Ethereum public blockchain for settlement, connected to the Swiss Interbank Clearing (SIC) payment system.

Capital requirements:
  • Small facility (annual trading volume ≤ CHF 250 million, custody ≤ CHF 100 million): CHF 500,000
  • Large facility without custody/settlement/clearing: CHF 1 million
  • Large facility with custody/settlement/clearing: CHF 5 million
  • FINMA may increase minimums by up to 50%

Legal basis: FMIA Art. 73a ff.

VASP Obligations Under Swiss Law

All Virtual Asset Service Providers (VASPs) operating in or from Switzerland must comply with:

  • Identity verification for all transactions exceeding CHF 1,000 (stricter than the FATF threshold)
  • Travel Rule: originator and beneficiary information must be transmitted with every transaction. Switzerland was one of the first jurisdictions to implement this (January 2020). FINMA goes beyond FATF by prohibiting fund transfers to unregulated wallet providers.
  • Five-year record retention for all transaction data
  • Suspicious activity reporting to the Money Laundering Reporting Office (MROS)

VASP Obligations Under Swiss Law

All Virtual Asset Service Providers (VASPs) operating in or from Switzerland must comply with:

  • Identity verification for all transactions exceeding CHF 1,000 (stricter than the FATF threshold)
  • Travel Rule: originator and beneficiary information must be transmitted with every transaction. Switzerland was one of the first jurisdictions to implement this (January 2020). FINMA goes beyond FATF by prohibiting fund transfers to unregulated wallet providers.
  • Five-year record retention for all transaction data
  • Suspicious activity reporting to the Money Laundering Reporting Office (MROS)

Crypto Custody: FINMA Guidance 01/2026

Published on 12 January 2026, this guidance sets supervisory expectations for all FINMA-supervised institutions offering crypto custody, trading, or investment services:

Segregation requirements (Art. 242a SchKG): For crypto assets to be excluded from a custodian's bankruptcy estate, two conditions must be met:
  1. The custodian has a contractual commitment to keep crypto assets available at all times
  2. The assets can be clearly allocated to individual owners or as a share in a collective holding

Individual vs collective custody: Omnibus wallets are permitted if off-chain records clearly identify each client's share at all times. Collective custody without clear allocation means clients become unsecured creditors in bankruptcy.

Delegation to foreign custodians is permitted only when:
  • The foreign custodian is subject to equivalent prudential supervision
  • Foreign law provides equivalent bankruptcy protection
  • The client has provided documented, informed consent

Private key governance: Institutions must implement access controls, dual controls, role separation, and change management procedures for private keys.

Staking: FINMA Guidance 08/2023

For banks to treat staked client crypto assets as off-balance sheet (avoiding capital adequacy impact):
  • Client must contractually agree to bear staking and provider default risk
  • Bank must conduct extensive due diligence on the staking provider
  • Staking provider must be subject to prudential supervision
  • Client disclosure must cover technical risks, counterparty risks, and market risks (lock-up periods, illiquidity)

What Is the Swiss Fintech Licence?

Switzerland offers a three-tier system for businesses that accept public deposits but do not operate as traditional banks. The fintech licence bridges the gap between the FINMA sandbox and a full banking licence:

Tier 1: Sandbox (No Licence Required)

Accept public deposits up to CHF 1 million total. No FINMA licence or SRO membership required for the deposit-taking activity. You must inform depositors that FINMA does not supervise the business and that deposits are not protected. Professional status is presumed at 20 or more depositors. Legal basis: Banking Ordinance Art. 6.

Tier 2: Fintech Licence

Accept public deposits up to CHF 100 million. Deposits must not be invested and no interest may be paid. Also covers collective custody of crypto-based assets.

  • Minimum capital: CHF 300,000
  • Processing time: 6–12 months
  • Lighter regulatory burden than a full banking licence
  • Legal basis: Banking Act Art. 1b

Tier 3: Full Banking Licence

Required above CHF 100 million in deposits, or when deposits are invested or interest is paid. Minimum capital: CHF 10 million. Full prudential supervision by FINMA. See how to obtain a FINMA licence for the step-by-step process.

Exemptions from Banking Licence

No fintech licence or banking licence is required when:
  • Client assets are backed by a bank guarantee covering the full amount
  • Maximum CHF 3,000 per person accepted for explicit product/service purchases
  • Each client's crypto assets are stored on individual blockchain addresses (not pooled)

FinSA Conduct Rules for All Financial Service Providers

The Financial Services Act (FinSA / FIDLEG), in force since 1 January 2020, imposes conduct rules on every entity that provides financial services in Switzerland — regardless of whether they hold a FINMA licence, a FinIA licence, or SRO membership.

Client Segmentation

Key Obligations

  • Suitability and appropriateness assessment before recommending financial instruments to retail clients
  • Key Information Document (KID) for financial instruments offered to retail clients
  • Prospectus requirement for public offerings of securities (with exemptions for offers to professional/institutional clients only)
  • Documentation and accountability: records of all advisory interactions
  • Ombudsman affiliation: all financial service providers serving retail clients must affiliate with a recognised ombudsman
  • Client adviser registration: individuals providing financial services must register with a FINMA-recognised registration body

FinSA and Trustees

Trust management is generally not a financial service under Art. 3(c) FinSA. Trustees acting exclusively in their capacity as trustees do not need ombudsman affiliation or client adviser registration. However, if a trustee also provides portfolio management or investment advice, those activities are subject to FinSA.

The Berne Financial Services Agreement (BFSA): UK–Switzerland

The BFSA entered into force on 1 January 2026. It is the first mutual recognition agreement for financial services between two major non-EU financial centres.

What It Covers

The BFSA covers wholesale and professional financial services only across seven sectors:

  1. Investment services (advisory, execution, order transmission) for professional clients
  2. Asset management and collective investment schemes
  3. Corporate banking (deposit-taking and lending)
  4. Wholesale insurance and reinsurance (excluding life insurance)
  5. OTC derivatives
  6. Financial market infrastructure (CCPs, trading venues, clearing)
  7. Certain digital-asset activities (tokenised securities and custody for professional clients)

How It Works

  • UK firms regulated by the FCA or PRA can serve Swiss professional clients without additional FINMA authorisation. They register on FINMA's BFSA register (confirmation within 60 days).
  • Swiss firms under FINMA supervision can access UK markets without separate FCA authorisation. They register with the FCA through electronic reporting.
  • UK client advisers are exempt from Swiss client adviser registration requirements under FinSA.

What It Does Not Cover

  • Retail financial services
  • Retail crypto platforms or stablecoin issuance
  • Life insurance
  • No binding dispute resolution mechanism

The BFSA operates on "outcomes-based regulatory deference" — each jurisdiction maintains independent rules, recognising the other's regulatory outcomes rather than harmonising standards.

Costs and Timelines

Estimated Costs by Authorisation Path

Additional Costs (All Paths)

Goldblum handles the entire process: company formation, compliance documentation, SRO application, and FINMA licence applications. Contact us for a cost estimate specific to your business model.

Post-Licence Compliance and Maintenance

Obtaining a licence or SRO membership is the beginning, not the end. Ongoing obligations apply regardless of which authorisation path you follow:

For All Financial Intermediaries

  • Physical Swiss office required (cannot operate as a mailbox company)
  • Resident director mandatory under Swiss corporate law
  • Staff must complete 40 hours of annual AML training
  • Annual audit by a FINMA-recognised audit firm
  • Five-year record retention for all client files, transactions, and AML documentation
  • Notify SRO/SO within 30 days of any material changes (directors, beneficial owners, business activities, address)
  • Suspicious activity reporting to MROS without delay

For FINMA-Licensed Institutions

  • Quarterly and annual regulatory reporting to FINMA
  • Capital adequacy monitoring and reporting
  • Compliance with FINMA circulars on risk management, outsourcing, and operational resilience
  • FINMA Circular 2026/1 (in force since 1 January 2026) requires integration of nature-related and climate financial risks into governance — primarily for banks and insurers

For Crypto Businesses

  • Comply with FINMA Guidance 01/2026 on crypto custody (segregation, private key governance, delegation due diligence)
  • Travel Rule compliance for all transactions
  • CARF reporting (Crypto-Asset Reporting Framework) — adopted by Swiss Parliament, implementation postponed to 2027 at the earliest

Proposed Changes: New Crypto and Payment Institution Licences (2027)

On 22 October 2025, the Swiss Federal Council opened a consultation on amendments to FinIA proposing two new FINMA-supervised licence categories to replace the current fintech licence. The consultation closed on 6 February 2026. Expected entry into force: 2027 at the earliest.

Payment Instrument Institution (Zahlungsmittelinstitute)

Replaces the fintech licence. Key changes:
  • Removes the CHF 100 million cap on client deposits
  • Allows issuance of regulated stablecoins (pegged to state-issued currency, conferring redemption rights)
  • Client funds must be segregated and automatically excluded from bankruptcy estates
  • Direct FINMA supervision (not SRO)
  • Must hold client funds as sight deposits with banks or in high-quality liquid assets

Banks cannot directly issue regulated stablecoins — they must establish separate Payment Instrument Institution entities. The Swiss Bankers Association has formally objected to this restriction.

Crypto-Institution (Krypto-Institute)

A new, lighter regulatory category for crypto businesses currently operating under SRO membership:
  • Custody of crypto-based assets (including custodial staking)
  • Client trading of crypto-based assets
  • Operating organised trading systems for crypto
  • Lighter than a securities firm licence
  • Proprietary trading and discretionary portfolio management remain outside scope — these require existing licences

Businesses currently operating under SRO membership will need to apply for this new licence once the law takes effect.

Switzerland vs EU MiCA

Frequently asked questions

A complete SRO application with professionally prepared AML documentation typically takes 2 to 3 months from submission to membership confirmation. The total process, including Swiss company formation and document preparation, takes 3 to 5 months. Delays occur most often because of incomplete beneficial owner identification, generic AML policies that do not reflect the applicant's actual business model, or a non-resident AML compliance officer.

Get in touch

Please contact us directly or via email if you require assistance. We are here to help you move forward.

Next Steps: Get Your Financial Services Licence in Switzerland

Whether you need SRO membership for a crypto exchange, a FINMA licence for asset management, or a fintech licence for deposit-taking, the regulatory path depends on your specific business model. The financial regulation team at Goldblum and Partners AG has guided over 200 businesses through Swiss financial licensing — from initial entity formation to FINMA approval.

For a preliminary assessment of which financial intermediary licence or FINMA authorisation applies to your business, contact Goldblum or call +41 44 51 52 590.

Last updated: March 2026
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Disclaimer: The information on this website is not intended to constitute legal advice or to create an attorney-client relationship. The information, documents, or forms provided here in are intended for general information purposes only and must not be regarded as legal advice. Laws change periodically; therefore, the information on this website may not be accurate. It is imperative that you seek legal counsel to ascertain your rights and obligations under the applicable law and based on your specific circumstances
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