VQF SRO Membership in Switzerland

VQF is a FINMA-recognised SRO

VQF is a private membership organisation recognised by FINMA to supervise AML compliance under the AMLA. Its regulations set out members' due-diligence duties and how VQF checks and enforces compliance. FINMA recognises and supervises the SRO itself; VQF carries out day-to-day supervision of its members. FINMA maintains the current list and guidance for recognised SROs.

An SRO affiliation is not a FINMA licence. It does not authorise banking, securities, fund or other activity that requires prudential authorisation. Our guide to FINMA licensing versus SRO membership explains how to distinguish the two routes.

Who may need VQF SRO affiliation

VQF affiliation may be appropriate where a business is a professional financial intermediary or adviser covered by the AMLA and is not supervised through a prudential licence or another statutory route. Examples can include payment, currency, fiduciary and some crypto-related activity, but labels do not decide the result. The handling of client assets, contractual relationships and decision-making must be mapped to the actual AMLA provisions.

The AMLA was amended with effect from 1 October 2026. FINMA's current guidance addresses financial intermediaries under Article 2 paragraph 3 AMLA and advisers under Article 2 paragraphs 3bis and 3ter. Check those provisions and the regulator's current SRO guidance before deciding whether a new or existing activity must affiliate.

Since the Financial Institutions Act came into force on 1 January 2020, a trustee or portfolio manager carrying on activity regulated by that Act follows the FINMA authorisation route and ongoing supervision through a FINMA-authorised supervisory organisation. The general distinction and application support are available through our SRO membership support.

Preparing a VQF application

A VQF application should show what the applicant does, who owns and manages it, and how its AML controls fit its business. Before filing, prepare a clear account of clients, products, jurisdictions, transaction flows and any custody or control over third-party assets.

• Confirm the legal classification of each planned activity under the AMLA and other financial-market laws.
• Describe the ownership, governance, responsible officers and organisation.
• Prepare the AML policy, risk assessment, client identification and beneficial-owner procedures, monitoring and reporting process.
• Gather corporate records, identity documents and any supporting agreements or process descriptions requested by VQF.
• Use the current VQF admission guidance and forms, submit the file, and answer review questions before commencing regulated activity.

VQF publishes application guidance, regulations and forms in its official document downloads. Forms and rules can change, so an older checklist may no longer describe the current application.

VQF fees and budgeting

VQF fees are set by the applicable fee regulations and vary with the membership category and activity. As of November 2026, use the current VQF Fee Regulations (Doc. No. 1101.5) and VQF guidance for admission, annual and audit costs; do not rely on older amounts quoted in third-party articles. VQF announced a revised fee structure effective from 1 January 2026, including changes to turnover-fee timing and hourly rates. Check the current documents before budgeting, per VQF fee regulations.

The fee schedule is only one part of the budget. The applicant should also account for its compliance function, client files, staff training, accounting and any external audit work required under the VQF rules. VQF's membership FAQ directs applicants to the applicable fee regulations.

VQF audits and ongoing member duties

A VQF member remains responsible for keeping its AML controls aligned with its actual business after admission. The member must follow the current VQF rules, retain adequate client and transaction records, train relevant staff, update VQF about changes where required and co-operate with the applicable AML review.

The audit looks for evidence that policies operate in practice: client and beneficial-owner identification, risk assessment, monitoring, escalation of suspicions, reporting and record keeping. VQF may require corrective action or apply measures under its regulations where it identifies a breach. FINMA supervises VQF's performance as a recognised SRO, including its regulations and oversight of members.

Keep evidence of affiliation current when presenting regulatory status to a bank, counterparty or client. Describe the status accurately as membership of a FINMA-recognised SRO; do not present it as a FINMA licence.

When this does not apply

VQF affiliation does not apply where the activity falls outside the AMLA, or where a different statutory supervisory route governs it. A business that requires a FINMA licence cannot use SRO membership as a substitute. Confirm the activity's classification before filing or starting operations.