Country guide · Europe

🇨🇭 Financial licensing in Switzerland

Banking, FinTech and SRO-based AML routes under a principles-based framework supervised by FINMA.

Switzerland offers several distinct routes for financial businesses. Deposit-taking on a professional basis requires a FINMA banking licence. The FinTech licence (Art. 1b Banking Act) allows accepting public deposits up to CHF 100 million provided they are neither invested nor bear interest. Many payment, crypto exchange and custody models that do not take deposits fall under the Anti-Money Laundering Act and require affiliation to a FINMA-recognised self-regulatory organisation (SRO). These routes are not interchangeable: SRO affiliation is AML supervision only and is not a licence to take deposits, manage collective custody or provide regulated securities services.

Regulators

Self-regulatory organisations recognised by FINMA (SRO)
AML supervision of affiliated financial intermediaries
Official website
Swiss Financial Market Supervisory Authority (FINMA)
Prudential supervisor: banks, FinTech licences, securities firms, SRO recognition
Official website

Licence and authorisation types

Banking licence

Swiss banking licence

Regulator: Swiss Financial Market Supervisory Authority (FINMA)
Permitted activities: Professional acceptance of public deposits, lending, payment accounts and full banking services.
Minimum capital: Minimum fully paid-up share capital of CHF 10 million (Banking Ordinance, Art. 15); actual capital set by risk and FINMA.
Ownership, management & substance: Effective management in Switzerland; adequate organisation, fit-and-proper board and management, separation of board and executive management.
Application procedure: Application to FINMA with business plan, organisational regulations, capital and liquidity planning, audit firm report.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: Foreign activities require separate authorisation in each target market.
Legal basis: Banking Act (BankA) Art. 3; Banking Ordinance

Swiss FinTech licence

Swiss FinTech licence (Art. 1b BankA)

Regulator: Swiss Financial Market Supervisory Authority (FINMA)
Permitted activities: Acceptance of public deposits up to CHF 100 million; deposits may not be invested or bear interest. Crypto-based assets may also be held under this licence category.
Minimum capital: Minimum capital of 3% of public deposits accepted, but at least CHF 300,000 (Banking Ordinance Art. 17a).
Ownership, management & substance: Registered office and effective management in Switzerland; simplified organisation compared to banks.
Application procedure: Application to FINMA; FINMA guidelines for FinTech licence applications apply.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: No lending with deposits, no interest; depositor protection scheme does not apply — clients must be informed.
Legal basis: Banking Act Art. 1b; Banking Ordinance Art. 14a ff.

Swiss SRO affiliation (AML supervision)

Financial intermediary affiliated to a Swiss SRO

Regulator: Self-regulatory organisations recognised by FINMA (SRO)
Permitted activities: Payment services, money transmission, money exchange, crypto exchange (fiat/crypto, crypto/crypto), certain custody and transfer services qualifying as financial intermediation under AMLA Art. 2(3).
Minimum capital: No statutory minimum capital under AMLA; SRO rules may set organisational and fit-and-proper conditions. Swiss company law minimum capital applies (e.g. CHF 100,000 for an AG).
Ownership, management & substance: Swiss company with persons responsible for AML; SROs typically require local compliance capability and audits.
Application procedure: Apply to an SRO of choice; submit organisation, AML directives, KYC procedures and fit-and-proper documents; annual SRO audit.
Government fees: Set by each SRO (membership and audit fees) — Verification required
Indicative timeline: No reliable published estimate
Limitations: AML supervision only. Does not permit deposit-taking; customer funds held beyond settlement periods may constitute deposits requiring a FinTech or banking licence. Does not authorise securities services or foreign-market activity.
Legal basis: Anti-Money Laundering Act (AMLA) Art. 2(3), 14

Virtual asset service provider (VASP)

Swiss crypto / VASP models (via SRO or FINMA licence)

Regulator: Self-regulatory organisations recognised by FINMA (SRO)
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.
Minimum capital: Depends on route: none under AMLA; FinTech or banking licence where client crypto-assets are held collectively without segregation.
Ownership, management & substance: Swiss operational presence; travel-rule compliant transfer processes (FINMA Guidance 02/2019).
Application procedure: Determine qualification with legal counsel; apply to SRO or FINMA accordingly.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: Operating a trading facility for DLT securities requires separate FINMA authorisation under the DLT framework.
Legal basis: AMLA; FINMA Guidance 02/2019; DLT Act amendments