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Compare financial licensing regimes
Select up to four jurisdictions and an activity group. Values come from our structured, sourced database; unknown values are shown as 'Verification required'.
Jurisdictions
Activity
| Criterion | 🇨🇭 Switzerland | 🇪🇺 European Union (passportable regimes) | 🇬🇧 United Kingdom |
|---|---|---|---|
| Regime | Swiss crypto / VASP models (via SRO or FINMA licence) | MiCA crypto-asset service provider | FCA cryptoasset registration (MLRs) |
| Reputation & stability | 10/10 Top-tier global reputation, political and monetary stability, neutrality and long financial tradition. | 8/10 Strong reputation; varies by member state. Passporting across the EEA. | 8/10 Major financial centre with a well-regarded regulator. |
| Regulator | SRO — Self-regulatory organisations recognised by FINMA | ESMA — European Securities and Markets Authority | FCA — Financial Conduct Authority |
| Permitted activities | Crypto exchange and transfer services generally qualify as financial intermediation requiring SRO affiliation; custody models differ depending on whether assets are segregated and attributable to clients. | Crypto-asset services under MiCA Art. 3(1)(16): custody, trading platform, exchange for funds or crypto, execution, placing, RTO, advice, portfolio management, transfer services. | Cryptoasset exchange and custodian wallet provision (AML registration). |
| Minimum capital | Depends on route: none under AMLA; FinTech or banking licence where client crypto-assets are held collectively without segregation. | EUR 50,000 / 125,000 / 150,000 depending on services (MiCA Art. 67 and Annex IV), or a quarter of fixed overheads if higher. | No prudential capital under MLR registration. |
| Substance & management | Swiss operational presence; travel-rule compliant transfer processes (FINMA Guidance 02/2019). | Registered office in the EU and at least one director resident in the EU; place of effective management in the EU. | UK presence expected. |
| Application procedure | Determine qualification with legal counsel; apply to SRO or FINMA accordingly. | Application to national competent authority; passporting through notification. | Registration application to FCA under the Money Laundering Regulations. |
| Government fees | Verification required | Varies by member state — Verification required | Verification required |
| Limitations | Operating a trading facility for DLT securities requires separate FINMA authorisation under the DLT framework. | Transitional (grandfathering) periods ended at the latest on 1 July 2026. | AML registration only; financial promotions regime applies; a full cryptoasset authorisation regime is being introduced. |
| Technology considerations | crypto, custody, kyc, aml, travel_rule, transactions, reporting | crypto, custody, kyc, aml, travel_rule, transactions, reporting, api | crypto, custody, kyc, aml, travel_rule, transactions, reporting |
| Source & verification | FINMA – FinTech Awaiting editorial verification | EUR-Lex – MiCA Awaiting editorial verification | FCA – Cryptoassets AML/CTF regime Awaiting editorial verification |
Comparisons are informational. Capital is a balance-sheet requirement, not a fee. Swiss SRO affiliation is AML supervision, not a prudential licence. Reputation & stability scores are our own editorial assessment, not regulator data.