VQF (Financial Services Standards Association, Zug) is a FINMA-recognised Self-Regulatory Organisation (SRO) under the Swiss Anti-Money Laundering Act. It issues AML rules for its members and monitors compliance via periodic audits and disciplinary powers.

When do we need SRO Membership with VQF versus a FINMA licence?

If you are a professional financial intermediary under AMLA and do not require a prudential licence, you meet AML duties through SRO Membership (e.g., VQF SRO). Independent portfolio managers and trustees require a FINMA licence and ongoing supervision by a Supervisory Organisation (SO).

What changed in 2020 with FinSA/FinIA?

From 1 January 2020, portfolio managers and trustees moved to a licensing regime (FinIA) with SO supervision. The DSFI route (direct AML supervision by FINMA) was abolished as of 31 December 2019. AMLA-only intermediaries typically use SRO membership for AML oversight.

Who performs the AML audits under SRO VQF?

Audits are carried out by accredited external auditors under VQF’s audit concept. VQF administers the process and may take disciplinary measures where required.

What are the headline fees in 2025?

Admission processing: CHF 2,000 + VAT (plus staff expenditure typically CHF 280–6,000). Admission audit if ordered: CHF 750–3,000 + VAT. Annual membership: CHF 400 + VAT. Supplementary annual fee: either AMLA file fee (CHF 30/20/10 per file by band) or AMLA turnover fee (CHF 500–10,000; > CHF 2m case-by-case). Minimum annual fee: CHF 1,250 + VAT. VQF admin fee for each AML audit: CHF 750 + VAT; the external auditor bills separately.

How do the AMLA file fee and AMLA turnover fee differ?

Traditional intermediation models usually pay per AML file (CHF 30/20/10 for 1–100/101–500/501+). Non-traditional or file-less models use the turnover-based fee (CHF 500–10,000). A minimum annual fee applies if the calculation would otherwise be lower.

Is there a minimum annual amount payable?

Yes. VQF sets a minimum annual fee of CHF 1,250 (plus VAT) if the file- or turnover-based charge would otherwise be lower.

Which documents are normally filed on joining VQF SRO?

The core pack typically includes Application 901.1 (companies) or 901.3 (natural persons), the business/activity description (901.2), Personal declaration 906.1, Consent to electronic dossier management 1200.1, plus organisational charts and governance attachments.

Does VQF accept crypto/VASP members?

Yes. VQF provides VASP-specific documentation (e.g., Doc-No. 807.2 for ownership/shareholding). Admission depends on the precise model and AML controls; crypto activity does not replace FinIA licensing where required.

May we outsource KYC or use an AMLA special department?

VQF permits outsourcing subject to control and documentation requirements. Ultimate responsibility remains with the member; use VQF’s guidance (e.g., information leaflet Doc-No. 912.1) when designing the arrangement.

How do counterparties verify our SRO status?

Banks and partners typically check FINMA’s public SRO member search to confirm your affiliation and the supervising SRO. Keep your entry aligned with corporate details.

Does SRO Membership authorise portfolio management or trusteeship?

No. Portfolio management and trusteeship require a FinIA licence and ongoing SO supervision. SRO Membership cannot substitute for a licence.

Is there an express or fast-track admission route?

Plan for ordinary processing. No express surcharge or guaranteed fast-track appears in the operative 2025 schedule.

Which language version of forms is legally binding?

English forms are available for convenience, but the German versions are legally binding.

Are training and re-testing addressed officially?

Yes. VQF publishes a Training Concept and lists courses and re-testing fees. Members should schedule induction and periodic refreshers, keeping attendance records.

What sanctions can VQF impose?

Depending on severity and culpability, VQF can pursue measures under its regulations and may levy a contractual penalty up to CHF 250,000. Additional costs may arise in measures/sanctions proceedings.

Where do we verify SO status and licensed firms under FinIA?

FINMA maintains public registers for authorised Supervisory Organisations and for portfolio managers/trustees licensed by FINMA.

We trade gold or crypto without custody—does AMLA/SRO still apply?

If your Swiss business professionally accepts or assists the transfer of assets for third parties, you are a financial intermediary under AMLA and must meet AML duties via an SRO unless you hold a prudential licence. The exact flow design determines the route.

What happens to fees when we resign from the SRO?

For the exit year, VQF calculates file- or turnover-based charges using the last reported figures and may perform plausibility checks if actuals cannot be verified after resignation.

We are a UK group launching in Switzerland. Any special equivalence?

There is no special UK equivalence. You must comply with Swiss regimes: either SRO Membership for AMLA-only intermediation or FinIA licensing with SO oversight. Verification is via FINMA’s public tools.

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VQF SRO in Switzerland: membership & fees

Knowledgebase

VQF SRO in Switzerland: membership & fees

Karin Gray

Associate

06.11.2025

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The VQF (Verein zur Qualitätssicherung von Finanzdienstleistungen) is one of the most prominent self-regulatory organizations (SROs) in Switzerland, officially recognized by FINMA. The VQF SRO supervises financial intermediaries that are not directly regulated by FINMA but are nonetheless subject to the Swiss Anti-Money Laundering Act (AMLA).

Businesses that typically fall under VQF Switzerland supervision include a wide range of financial intermediaries: companies engaged in crypto and blockchain-related activities (such as token issuance, crypto exchange, or investment), trading of precious metals, foreign currency exchange, and other financial services that require AML compliance.

Joining the VQF involves meeting specific membership criteria, preparing detailed compliance documentation, and undergoing a thorough review process. Once admitted, members are subject to periodic audits and continuous monitoring to ensure compliance with AML and KYC standards set forth under Swiss law.

At Goldblum and Partners, we have been assisting clients with VQF membership and compliance matters since 2013. Our experience includes advising traditional asset management firms as well as innovative fintech and blockchain ventures seeking to operate in full compliance with Swiss regulatory requirements.

Please note that the information provided herein is for general informational purposes only, may not reflect the most recent regulatory developments, and does not constitute legal advice.

8. How do we evidence our status to counterparties?
9. How does VQF relate to the BOVV/IOAM rules — and when is dual membership relevant?
10. Process flow — joining VQF SRO (what holds up under audit)
11. Comparative table — responsibilities under SRO VQF vs AO/SO
12. Data/spec table — minimum practical organisation for SRO Membership
13. Illustrative annual budget scenarios (for planning purposes only)
14. “Which rules apply to us?” — frequently decisive questions
15. Three targeted expert tips
16. Sources (official and primary)
17. FAQ

What is VQF and how does Swiss SRO oversight work?

The VQF (Financial Services Standards Association; Verein zur Qualitätssicherung von Finanzdienstleistungen, Zug) is an officially recognised Self-Regulatory Organisation (SRO) under Switzerland’s Anti-Money Laundering Act (AMLA). SROs issue binding AML rules for their members and monitor compliance through periodic audits and disciplinary powers. They are not prudential supervisors. In practice, professional financial intermediaries (PFIs) that are not licensed by FINMA must satisfy AML duties by joining an SRO such as VQF and submitting to its rulebook and audits.

What does that mean in practice?

Members adopt the SRO’s AML regulations, implement internal controls (customer identification, beneficial owner verification, risk assessment, ongoing monitoring and suspicious activity reporting), maintain records, train staff and accept external AML audits under the SRO’s audit concept. FINMA recognises and oversees SROs, but the day-to-day monitoring of members sits with the SRO.

How did the 2020 FinSA/FinIA reforms change the map?

On 1 January 2020, the Financial Services Act (FinSA/FIDLEG) and the Financial Institutions Act (FinIA/FINIG) re-drew the boundary between AMLA/SRO oversight and prudential licensing:

Independent portfolio managers and trustees now require a FINMA licence and are under ongoing prudential supervision by Supervisory Organisations (AO/SO) that are authorised and monitored by FINMA.
The legacy status of directly subordinated financial intermediaries (DSFI/DUFI) under AMLA was abolished with effect from 31 December 2019; from 1 January 2020 these firms are no longer under direct AML supervision by FINMA.

Comparative table — before vs after 2020 (high level)

Topic	Before 2020	After 2020
Portfolio managers & trustees	Often within AMLA/SRO perimeter without a prudential licence	Must be licensed by FINMA; ongoing AO/SO supervision
DSFI (directly subordinated AML supervision by FINMA)	Existed as an alternative to SRO membership for some PFIs	Abolished 31.12.2019; AML-only PFIs use SRO membership
Role of SROs	AML rules & monitoring for affiliated intermediaries	Same role; continue for AML-only PFIs
Role of FINMA	Recognises SROs; licensed sectors under prudential supervision	Recognises SROs & SOs; licences FinIA institutions; DSFI route discontinued

Sources: FINMA pages on SROs and SOs; FINMA notice that DSFI status was cancelled with effect 31.12.2019. (FINMA)

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Do you need SRO membership or a FINMA licence?

Use the underlying activity—not your marketing label—to determine the route:

Your planned activity	Primary regime in 2025	What this implies
Discretionary portfolio management for clients	FinIA licence; ongoing AO/SO supervision	Apply for FINMA licence; AO/SO monitors prudentially. SRO membership cannot substitute. (FINMA)
Acting as a trustee	FinIA licence; AO/SO supervision	As above. (FINMA)
Banking or securities firm services	Bank/Securities firm licence	Prudential regime; outside SRO membership model. (FINMA)
Professional financial intermediation under AMLA without a prudential licence (e.g., certain payment-adjacent flows, brokers outside securities-firm status, finance companies handling client assets)	SRO Membership (e.g., VQF SRO)	Implement AML controls under SRO rulebook; periodic AML audits. (FINMA, vqf.ch)

Expert tip (scope mapping): Before choosing tools or templates, write a short legal memo mapping every revenue line to AMLA and FinIA definitions. This mapping dictates whether SRO Membership suffices or a FINMA licence is mandatory; it will also drive organisation charts, budget and timelines.

Who typically uses VQF SRO in 2025?

Common candidates include businesses that professionally accept, hold, arrange or transfer assets for third parties without engaging in licensed banking/securities/FinIA-licensable activities—for example, some payment facilitation or credit-broking models where client money handling triggers AMLA but not a prudential licence. Each design requires individual analysis; similar-sounding models can land on different sides of the line depending on custody, discretion and counterparty structure.

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What does SRO VQF expect in organisation and controls?

At a minimum, expect (i) board accountability for AML, (ii) a named AML/MLRO function, (iii) written policies covering KYC, beneficial ownership, PEP/sanctions, SoF/SoW, risk assessment, ongoing monitoring and reporting to MROS, (iv) record-keeping and training, and (v) periodic external AML audits under VQF’s audit/control concept.

What documents are filed at admission?

Core admission pack items include the Application for SRO membership (VQF Doc-No. 901.1 for legal entities; 901.3for natural persons), the business/activity description (on VQF’s forms), personal declarations (VQF 906.1) and the consent to electronic dossier management (VQF 1200.1). VQF confirms that 901.1/901.3 and 1200.1 may be lodged electronically (no original by post) if signed appropriately.

Data/spec table — key VQF forms you will actually use

Purpose	VQF document
Admission – legal entities	901.1 (Application; English/German versions available)
Admission – natural persons	901.3
Personal declarations (management, AML function, qualified holders)	906.1
Consent to electronic dossier management	1200.1
Client identification (onboarding)	902.1
Beneficial owner	902.9
Controlling person (as applicable)	902.11
File list template	902.8

Sources: VQF form pages and downloads.

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Fees and budgeting: the numbers VQF SRO publishes

VQF’s Fees Regulations (VQF Doc-No. 1101.5) set out admission, membership and audit charges. Note that the Express admission option was discontinued from 1 July 2019; all files are processed under the ordinary route.

Data/spec table — headline fees (SRO)

Category	Amount (CHF)	Notes
Admission processing (SRO and/or IOAM/BOVV)	1,800 + VAT	One-off processing fee. vqf.ch
Admission review (if ordered)	750–3,000 + VAT	Time-spent range; by Supervisory Commission decision. vqf.ch
Annual membership fee (active or passive)	400 (VAT-free)	VQF membership fee. vqf.ch
Annual AMLA file-based fee	30 / 20 / 10 per file	Segments 1–100 / 101–500 / 501+ files. vqf.ch
Annual AMLA turnover-based fee	500–10,000 + VAT	Banded by turnover; used for non-traditional models. vqf.ch
BOVV/IOAM annual fee (if applicable)	500 + VAT	Cumulative if combined with SRO membership. vqf.ch
VQF admin fee per AML audit	500 + VAT	Plus time-based elements below. vqf.ch
VQF time-based audit items	CHF 250/hr (inspection & processing), CHF 125/hr (travel)	External audit firm bills separately on time-spent. vqf.ch

Important: Express handling is no longer available (abolished from 1 July 2019). Budget accordingly for the ordinary route.

Data/spec table — AMLA file-fee bands (SRO)

AML files (maintained + opened in the year)	Fee per file (CHF)
1–100	30
101–500	20
501+	10

Source: VQF Fees Regulations, para 2.2.1.

Data/spec table — AMLA turnover-fee bands (SRO)

Annual turnover (CHF)	Annual fee (CHF)
1–100,000	500–1,500
100,001–250,000	1,501–3,000
250,001–500,000	3,001–5,000
500,001–1,000,000	5,001–7,500
>1,000,000	7,501–10,000

Source: VQF Fees Regulations, para 2.2.2.

Comparative table — SRO VQF vs AO/SO cost drivers

Aspect	VQF SRO (AMLA-only PFIs)	AO/SO (FinIA-licensed firms)
Admission	SRO processing fee; possible admission review	FINMA licence application; SO onboarding
Recurring	Membership + AMLA file/turnover fee; AML audit admin fee; external audit time	SO annual levy/fees; prudential audits; regulatory reporting
External audit	AMLA audit by approved external auditor (time-spent)	Prudential audit/reporting under SO framework
Training	AML training (VQF courses available)	Prudential + AML training; broader governance expectations

Sources: VQF fees regulation; FINMA pages on SROs and SOs.

Expert tip (budget realism): there is no universal “audit from CHF 3,000” package in the SRO rules. Actual external audit cost depends on your volumes, file quality and systems; VQF’s own schedule lists only the admin fee and internal hourly rates. Assume the external firm will charge by time on scope. (vqf.ch)

How does the SRO VQF audit work?

Infographic (process in words):

Planning & scoping

risk-based approach; selection of files and topics.
On-site/remote inspection

sampling AML files, interviewing staff, reviewing systems.
Findings & remediation

actions agreed with deadlines; possible disciplinary steps for material breaches.
Follow-up

remediation verified; issues tracked into the next cycle.

VQF’s regulations provide the framework; audits are performed by accredited external auditors and supported by VQF’s audit/admin processes. VQF charges a flat CHF 500 admin fee and time-based rates for its own tasks; the external auditor bills separately.

Data/spec table — audit cost components you should expect

Component	Who charges it	Basis
VQF admin fee	VQF	CHF 500 per AML audit (+ VAT)
VQF processing/inspection time	VQF	CHF 250/hr (processing/inspection), CHF 125/hr (travel)
External audit firm fees	External auditor	Time-spent per engagement letter; scope depends on risk/volumes

Source: VQF Fees Regulations, section 7.

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How do we evidence our status to counterparties?

Counterparties (banks, PSPs, partners) can verify SRO affiliation using FINMA’s SRO Member Search. Ensure your legal name and details are consistent across the SRO, the FINMA public tool and your own materials to avoid onboarding friction.

Expert tip (public footprint): many bank onboarding delays arise from discrepancies between the FINMA search entry, your SRO records and what your website claims. Align them first; it is a controllable risk.

How does VQF relate to the BOVV/IOAM rules — and when is dual membership relevant?

Alongside its SRO role, VQF is also the Industry Organisation for independent Asset Managers (BOVV/IOAM) with FINMA-recognised rules of professional conduct (since 23 April 2009). Where relevant to your services, BOVV membership can be held in addition to SRO membership; fees are cumulative (BOVV flat rate CHF 500 p.a.). This does not replace a FinIA licence where one is required.

Process flow — joining VQF SRO (what holds up under audit)

Infographic (admission steps):

Scope mapping

classify every activity against AMLA (financial intermediation) and FinIA (licensable services).
Policy build

adopt AML policies & procedures proportionate to your model; align with VQF forms.
Organisation

appoint an AML/MLRO; define reporting lines; prepare training plan and MI.
Prepare the file

901.1/901.3, activity description, 906.1, 1200.1, org charts and registers.
Submit & respond

address SRO queries; admission review if ordered; lodge electronic signatures as allowed.
Audit readiness

select an accredited external auditor; schedule training; run internal file quality checks.

Sources: VQF admission guidance and form pages; newsletter confirming e-submission of 901.1/901.3 and 1200.1.

Comparative table — responsibilities under SRO VQF vs AO/SO

With a thorough market analysis in hand, it’s time to define your marketing strategy. This section outlines how your product or service will reach its intended audience and how you will generate visibility, leads, and ultimately revenue.

Area	SRO VQF (AMLA)	AO/SO (FinIA)
Rulebook	AML due-diligence rules; reporting to MROS	Prudential requirements; organisation, risk, conduct under FinIA/FinSA
Supervision	SRO monitors members; audits via accredited auditors	SO monitors licensees on an ongoing basis; FINMA licenses and enforces
Public check	FINMA SRO Member Search	FINMA “Authorised institutions” register; SO listed by FINMA
Sanctions	SRO disciplinary powers; may escalate	FINMA enforcement; SO measures within remit

Sources: FINMA pages on SROs and SOs.

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Data/spec table — minimum practical organisation for SRO Membership

Every business needs a compelling sales pitch — a clear, concise articulation of what your company does, why it matters, and why people should care. This section ties closely with marketing but focuses more on direct customer engagement.

Function / artefact	Expectation
Board oversight	Formal responsibility for AML controls and remediation
AML/MLRO	Named individual with authority and access
Onboarding pack	Use VQF 902.1 (ID), 902.9 (BO), 902.11 (controlling person), file list 902.8
Risk assessment	Documented client/product/geography/channel risks; PEP/sanctions screening
Ongoing monitoring	Risk-based triggers; periodic reviews; event-driven checks
Reporting	Procedures for red flags and reporting to MROS
Training	Initial and periodic AML training; attendance logs and testing
Records	Retention and retrieval aligned to AMLA and VQF rules

Sources: VQF regulations; form suite; FINMA SRO page (AMLA obligations).

Illustrative annual budget scenarios (for planning purposes only)

Assumptions: figures reflect published VQF fees plus indicative external audit hours for illustration; external auditors bill time-spent and will vary by risk/volume.

Scenario (AMLA-only PFI)	Files / turnover	VQF fixed	VQF variable	External audit (illustrative)	Total (ex-VAT)
A — Low-volume introducer	50 files	400	50×30 = 1,500	20h × (auditor’s rate, not in VQF tariff)	1,900 + auditor
B — Mid-volume	300 files	400	100×30 + 200×20 = 7,000	35–50h × (auditor’s rate)	7,400 + auditor
C — Turnover-based model	CHF 600k	400	5,001–7,500	30–45h × (auditor’s rate)	5,401–7,900 + auditor

Source for VQF components: VQF Fees Regulations (membership, file-fee bands; turnover bands; audit admin fee).

“Which rules apply to us?” — frequently decisive questions

– We offer crypto brokerage but do not hold client assets. Do we still need SRO Membership?

If the activity qualifies as professional financial intermediation (arranging transfers of assets on a professional basis), the AMLA route with SRO Membership is typically required, even if you do not prudentially hold a licence. The exact setup matters (custody, fiat rails, trading arrangements).

– We are an asset manager; can VQF SRO membership alone cover us?

No. Asset managers require a FinIA licence with AO/SO supervision; SRO Membership does not authorise portfolio management or trusteeship.

– Can we show banks a certificate to prove our AML oversight?

Counterparties will generally check FINMA’s public SRO Member Search. Keep that entry aligned with your corporate data.

Three targeted expert tips

Design before documentation

Align the business model to the correct regime first (SRO Membership vs licence with AO/SO). Building controls for the wrong lane is the costliest mistake at admission and first audit.
Lock your onboarding pack

Use the VQF 902-series forms consistently; weak SoF/SoW narratives and ownership charts are the fastest way to escalate audit scope (and cost).
Don’t plan for “Express”

VQF discontinued express processing on 1 July 2019; timetable your admission and budgeting on the ordinary route.

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Sources (official and primary)

FINMA — Self-regulatory organisations (SROs); public SRO member search; AMLA link.
FINMA — Supervisory organisations (SO) for portfolio managers and trustees.
FINMA — Portfolio managers and trustees licensing/supervision.
FINMA — Notice that DSFI status was cancelled as of 31.12.2019. (finmasearch.org)
VQF — SRO overview; Centre of Competence.
VQF — Fees Regulations (VQF Doc-No. 1101.5).
VQF — Express processing discontinued (news, 2019).
VQF — Admission forms (901.1, 901.3), Personal declaration 906.1, Electronic dossier consent 1200.1; 902-series onboarding forms.

FAQ

VQF (Financial Services Standards Association, Zug) is a FINMA-recognised Self-Regulatory Organisation (SRO) under the Swiss Anti-Money Laundering Act (AMLA). It issues AML rules for its members and monitors compliance via periodic audits and disciplinary powers.