Switzerland regulates fintech and crypto businesses through its existing financial market laws rather than a single crypto statute. The activity decides the route. FINMA, the Swiss Financial Market Supervisory Authority, licenses and supervises institutions that accept deposits, trade securities or operate trading venues. Businesses that only move, exchange or hold assets for clients are financial intermediaries under the Anti-Money Laundering Act and are supervised through a self-regulatory organisation (SRO) recognised by FINMA.
Two questions settle most cases. First, does the business hold client money or crypto-based assets on its own balance sheet? Second, is the business a financial intermediary acting on a professional basis? The full requirements for each route are set out on the Switzerland fintech licence and Switzerland crypto licence pages.
Under the Banking Ordinance, accepting more than 20 public deposits on a continuing basis is a commercial activity that needs a licence. Several balances do not count as deposits. Settlement balances that pay no interest, are used only to process client transactions and are cleared within 60 days are excluded. FINMA lists further exemptions: amounts covered by a bank guarantee, small balances of up to CHF 3,000 per person held to buy goods or services, and crypto-based assets kept on an individual blockchain address for each client. A business accepting no more than CHF 1 million of public deposits, with no interest margin business and a written warning to depositors that FINMA does not supervise it, also falls outside the licence requirement under Article 6 of the Banking Ordinance.
Payment services, issuing or managing means of payment, money or value transfer, currency trading and asset management make a business a financial intermediary under Article 2(3) of the Anti-Money Laundering Act. The Anti-Money Laundering Ordinance treats virtual currencies used for payments or transfers as means of payment. An intermediary acts on a professional basis if, in a calendar year, it earns gross revenue above CHF 50,000, has business relationships with more than 20 contracting parties, carries out transactions above CHF 2 million in total, or at any time controls third-party assets above CHF 5 million. Money or value transfer is professional at any scale, except for closely related persons below CHF 50,000 of gross revenue.
| Business model | Route | Legal basis |
|---|---|---|
| Crypto exchange or broker, custody on individual client addresses | SRO membership | Anti-Money Laundering Act, Article 2(3) |
| Payment, money transfer, card or prepaid business holding no deposits | SRO membership | Anti-Money Laundering Act, Article 2(3) |
| Wallet, payment account or pooled crypto custody up to CHF 100 million | Fintech licence | Banking Act, Article 1b |
| Multilateral venue for DLT securities with retail access, custody or settlement | DLT trading facility licence | Financial Market Infrastructure Act, Articles 73a and following |
| Trading securities in its own name for clients | Securities firm licence | Financial Institutions Act |
| Deposits above CHF 100 million, or deposits that are lent or pay interest | Banking licence | Banking Act, Article 3 |
Each route carries a different level of supervision and capital. The table sets out what each permits and the minimum capital the law or FINMA states.
| Route | What it permits | Minimum capital |
|---|---|---|
| SRO membership | Payment, exchange, brokerage and non-pooled custody, supervised for anti-money laundering purposes | No FINMA requirement; the SRO's own rules apply |
| Deposit exemption (Banking Ordinance, Article 6) | Public deposits up to CHF 1 million without interest margin business | None |
| Fintech licence | Public deposits or crypto-based assets up to CHF 100 million, not invested and paying no interest | 3% of deposits, at least CHF 300,000 |
| DLT trading facility | Multilateral trading of DLT securities, with retail access, central custody or settlement | Set by the Financial Market Infrastructure Ordinance |
| Securities firm | Trading securities for clients | CHF 1.5 million, fully paid up |
| Bank | Unlimited public deposits, lending and interest | CHF 10 million, fully paid up |
A financial intermediary that is not supervised by FINMA as an institution must join an SRO recognised under Article 14 of the Anti-Money Laundering Act. The SRO sets the due diligence rules in regulations approved by FINMA, checks that members comply through periodic audits and can impose sanctions up to exclusion. FINMA supervises the SROs, not their members. FINMA recognises ten SROs, including VQF, PolyReg, ARIF, AOOS, SO-FIT and SRO-Treuhand Suisse. FINMA's 2025 annual report confirms that crypto service providers are currently supervised by SROs for anti-money laundering purposes only.
The fintech licence was created for companies mainly active in finance that accept public deposits of up to CHF 100 million, or crypto-based assets held in collective custody, without investing them or paying interest. It carries lighter requirements than a banking licence. Deposits are not privileged in bankruptcy and are not covered by deposit insurance, and clients must be told so before they deposit. In special cases, Article 1b(5) of the Banking Act allows FINMA to apply the regime above CHF 100 million where the company protects clients through special measures. FINMA's register listed six Article 1b licensees in October 2026.
The Federal Act on the Adaptation of Federal Law to Developments in Distributed Electronic Register Technology, known as the DLT Act, took effect in part on 1 February 2021 and in full on 1 August 2021, according to the State Secretariat for International Finance. It introduced ledger-based securities, increased legal certainty in bankruptcy and created the DLT trading facility licence. A DLT trading facility trades DLT securities multilaterally under non-discretionary rules and either admits retail clients, holds DLT securities in central custody or clears and settles them. It must be a legal entity under Swiss law with its registered office and head office in Switzerland. FINMA granted the first DLT trading facility licence on 18 March 2025, for a small facility with regulatory relief within thresholds set by the ordinance.
A company that accepts public deposits above CHF 100 million, or that invests deposits or pays interest on them, is a bank. FINMA requires fully paid-up capital of at least CHF 10 million, separate strategic and executive management, management from Switzerland, effective risk management and an internal audit function independent of executive management. A business that trades securities in its own name for clients holds a securities firm licence with at least CHF 1.5 million of fully paid-up capital.
The requirements below apply to the fintech licence under Articles 14a to 14g and 17a of the Banking Ordinance. The banking licence and the DLT trading facility licence build on the same principles with higher standards.
Minimum capital is 3% of the public deposits accepted and crypto-based assets held in custody, and at least CHF 300,000. It must be fully paid in, maintained at all times and not lent to qualified participants or invested in companies they control. FINMA may require more capital where the risks call for it. The application shows how capital keeps pace with deposit growth across the business plan.
The company is a company limited by shares (AG), a partnership limited by shares or a limited liability company (GmbH), with its registered office and actual management in Switzerland. The business is managed from Switzerland, and managers live where they can run it effectively and responsibly. Managers must have a good reputation and offer assurance of proper business conduct, and qualified participants file FINMA's declarations on their holdings, proceedings and other mandates.
The articles define the business scope precisely, in line with the company's financial resources and organisation. Where the business requires a governing body for supervision and control, it has at least three members, at least one third of them independent of management. Risk management and compliance are independent of the revenue-generating units. FINMA may grant relief from this separation to a company with gross income below CHF 1.5 million that shows a low-risk business model. Organisational measures address conflicts of interest, and any that cannot be excluded are disclosed to clients.
Client deposits and crypto-based assets in custody are held separately from own funds, or recorded so that they can be shown separately at any time. Deposits are held as sight deposits or as Category 1 high-quality liquid assets, in the currency owed to clients. Crypto-based assets are held in Switzerland in the form received. Before contracting, clients receive written information on the risks of the business model, services and technology and on the absence of deposit insurance, and that information may not sit only in the general terms.
Every route carries the due diligence duties of the Anti-Money Laundering Act: identifying the contracting party and the beneficial owner, monitoring business relationships and reporting suspicions to the Money Laundering Reporting Office Switzerland. For crypto transfers, FINMA Guidance 02/2019 requires sender and beneficiary information to travel with each transfer. Supervised institutions may send tokens only to external wallets of their own verified clients and receive tokens only from them, with no exemption for unregulated wallet providers.
Accounts follow the Code of Obligations and are audited annually. The regulatory audit is performed by an audit firm approved by the Federal Audit Oversight Authority. FINMA decides case by case whether to order a licensing audit report before granting a fintech licence; for a DLT trading facility, an audit firm reviews the applicant in every case before the licence is granted.
FINMA charges for its licensing work under the FINMA Fees and Levies Ordinance. Once licensed, each institution pays an annual supervisory levy. SRO admission and membership fees are set by each SRO in its own regulations.
| Item | Amount | Basis |
|---|---|---|
| FINMA licensing work | CHF 100 to CHF 500 per hour | Charged by time, by staff level and the importance of the matter (Article 8) |
| Authorisation enquiry | Normally subject to a fee | FINMA analysis of whether a licence is required |
| Annual base levy, fintech licence | CHF 3,000 | Per Article 1b licensee (Article 19e) |
| Annual variable levy, fintech licence | Share of FINMA's costs | Two tenths by balance sheet total, eight tenths by gross income (Article 19f) |
| Licensing audit report | Set by the audit firm | Where FINMA orders one; always for a DLT trading facility |
| Minimum capital, fintech licence | CHF 300,000 | Or 3% of deposits and custodied assets if higher |
FINMA sets no statutory decision period for any of these licences. Its pages state that duration depends on the complexity of the project and the quality and completeness of the application. The stages, and the deadlines the law does set, are below.
| Stage | What happens | Timing |
|---|---|---|
| Authorisation enquiry | FINMA assesses whether the model needs a licence, filed through its survey and application platform (EHP) | DLT and crypto enquiries answered in under 30 days on average in 2025 |
| Project presentation | Optional meeting to present the licensing project before filing | Before the application |
| Application | FINMA names the case officer and lists missing information or documents | No statutory period |
| Licensing audit | Audit firm report where ordered, and always for a DLT trading facility | Before the decision |
| Licence | Operations start only once FINMA grants the licence | On decision |
| Deposits above CHF 1 million | Notify FINMA and apply for a licence | Within 10 days and 30 days |
| Deposits above CHF 100 million | Notify FINMA and apply for a banking licence | Within 10 days and 90 days |
Preparation drives the timetable. FINMA's 2025 annual report records about 30 fintech licence applications since 2019, mostly for fiat payment services, and seven companies licensed by the end of 2025. It names the reasons a relatively large share did not qualify: insufficient preparation, no transparent source of funds, concerns about business conduct, prior activity abroad and opaque group structures. FINMA recommends its preliminary project review, which flags licensing obstacles early.
Banking is a licence condition, not a later step. A fintech licensee holds client deposits as sight deposits at a bank or in Category 1 high-quality liquid assets, so the deposit account is in place before the business accepts client money. An SRO member that processes payments or exchanges fiat for crypto needs operating and client accounts that its bank is comfortable with from the first transaction.
Swiss banks review the same points FINMA and the SROs examine: a transparent source of funds for the shareholders, a clear group structure, the anti-money laundering framework, the travel rule controls for crypto transfers and the custody arrangements. FINMA's Guidance 01/2026 on the custody of crypto-based assets adds that an institution using sub-custodians in Switzerland or abroad keeps full responsibility, and that client assets must stay outside the custodian's bankruptcy estate. Banks expect this to be documented.
The accounts and infrastructure are opened in parallel with the application through banking and payment processing, so the business can trade from the day the licence is granted.
Supervision continues from the first day of operations. For a fintech licensee the recurring obligations are set by the Banking Act, the Banking Ordinance and FINMA's guidelines.
FINMA supervises closely. Its 2025 annual report states that most fintech licensees were at times under intensive monitoring because of tight capital and liquidity, and that it withdrew one licence where in-house software was worth far less in liquidation than as a going concern. A three-year plan with conservative assumptions, and capital that stays ahead of deposit growth, are the basis of a stable licence.
SRO members receive periodic AML audits from their SRO, report suspicions to the Money Laundering Reporting Office Switzerland.
On 22 October 2025 the Federal Council opened a consultation on an amendment to the Financial Institutions Act. It proposes two new licence categories.
The consultation closed on 6 February 2026. As of 18 October 2026, the State Secretariat for International Finance gives no date for the dispatch to Parliament or for entry into force. Article 1b of the Banking Act, SRO membership and the DLT trading facility licence remain the routes in force today. A business licensed now under Article 1b, or affiliated to an SRO, is the natural applicant for the new categories once they are enacted, and its capital, custody and governance can be designed with the proposed standards in mind.
The right route follows from the business model, the client base and the growth plan. Five steps settle it.
For crypto businesses comparing Switzerland with the EU, the MiCA licence guide sets out the EU requirements side by side. A group can hold both: a Swiss entity for custody, tokenisation and Swiss clients, and an EU authorisation for passporting across the single market.
Not a single one. FINMA applies existing law to crypto businesses: SRO membership under the Anti-Money Laundering Act for exchange, brokerage and custody on individual client addresses, the fintech licence for pooled custody, and the DLT trading facility licence for venues trading DLT securities.
An exchange or broker that keeps each client's crypto on an individual blockchain address and holds no deposits joins a FINMA-recognised SRO for anti-money laundering supervision. Pooled custody of client crypto-based assets needs the fintech licence.
3% of the public deposits accepted and crypto-based assets held in custody, and at least CHF 300,000. It is fully paid in, maintained at all times and not lent to qualified participants. FINMA may require more where risks call for it.
There is no statutory decision period. FINMA states that duration depends on the complexity of the project and the quality and completeness of the application. In 2025 it answered DLT and crypto enquiries in under 30 days on average.
Licensing work is charged by time at CHF 100 to CHF 500 per hour. A fintech licensee then pays an annual base levy of CHF 3,000 plus a variable levy by balance sheet total and gross income. SRO fees are set by each SRO.
The fintech licensee notifies FINMA within 10 days and applies for a banking licence within 90 days. In special cases FINMA may keep the fintech regime above CHF 100 million where clients are protected by special measures.
The Federal Council has proposed a payment instrument institution licence to replace it, without the CHF 100 million cap. The consultation closed on 6 February 2026, and no date for entry into force has been published.
No. Switzerland is outside the EU and the EEA, so a Swiss licence carries no passport. A group serving EU clients holds a separate EU authorisation, such as a MiCA crypto-asset service provider authorisation.
Buckingham Capital Consulting obtains fintech licences, SRO memberships and crypto authorisations in Switzerland and more than 60 other countries, and arranges the banking and technology each licensed business needs.
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This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.