World consultancy EY has launched a brand new licensing information for market contributors in Switzerland, providing sensible steering for business gamers together with fintech companies, distributed ledger know-how (DLT) buying and selling platforms, and cost system operators.
It gives an outline of the principle forms of FINMA licenses and authorizations, outlines key regulatory frameworks, and explains particular necessities.
The information identifies 5 principal authorized acts governing Switzerland’s monetary sector underneath the supervision of the Swiss Monetary Market Supervisory Authority (FINMA): the Banking Act (BA), the Insurance coverage Supervision Act (ISA), the Monetary Market Infrastructure Act (FinMIA), the Monetary Establishments Act (FinIA), and the Collective Funding Schemes Act (CISA).
It additionally highlights the Anti-Cash Laundering Act (AMLA) and the Monetary Providers Act (FinSA), which have an effect on the monetary providers sector however which fall outdoors of FINMA’s direct supervisory scope.
The Fintech License
For fintech firms, BA is the core regulation. Below this regulation, the Fintech License permits firms to just accept public deposits with out participating in conventional banking actions corresponding to lending or paying curiosity. Launched in January 2019, it gives a decrease regulatory burden than a full banking license, whereas nonetheless requiring compliance with anti–cash laundering guidelines and sturdy threat administration.
The license permits holders to just accept as much as CHF 100 million in public deposits or crypto-assets, with out investing or paying curiosity on them. Against this, a standard banking license targets establishments accepting deposits above CHF 100 million, investing or paying curiosity on these deposits, and offering financing on their very own account whereas refinancing extensively with different banks.
Eligible candidates embrace restricted firms, partnerships with limitless companions, and restricted legal responsibility firms, and minimal capital should equal a minimum of 3% of public deposits and crypto-assets held in collective deposit, with a ground of CHF 300,000, absolutely paid up and maintained always.
Governance necessities embrace administration situated in Switzerland, a minimum of a 3rd of the governing physique impartial of administration, and assurance of irreproachable enterprise conduct by key contributors and administration.
Licensees should additionally implement efficient threat administration methods protecting market, credit score, default, settlement, liquidity, picture, operational and authorized dangers. They need to keep clear separation of inner features, particularly lending, buying and selling, asset administration and settlement, and have an impartial inner audit operate. They need to additionally appoint a acknowledged regulatory audit agency for ongoing supervision.
Similar to the banking license, the Fintech License additionally comes with prices, that are lined by charges and supervisory levies. To handle these, FINMA has created a brand new part in its Charges and Levies Ordinance particularly for Fintech License holders.
The supervisory levy features a mounted fundamental levy of CHF 3,000 plus an extra levy calculated as 20% primarily based on the corporate’s stability sheet complete, and 80% primarily based on the corporate’s gross earnings.
On prime of those levies, firms should additionally pay for related monetary and regulatory audits, payable to the respective audit firms. FINMA estimates this quantity to be round CHF 40,000 to CHF 50,000, which is considerably lower than what’s due for an everyday banking license.
DLT Buying and selling Services
Along with BA, FinMIA is one other key regulation for fintech firms, particularly these working digital asset buying and selling platforms and cost methods.
Monetary market infrastructure teams, together with DLT buying and selling platforms, should apply for licensing as a DLT Buying and selling Facility. A DLT Buying and selling Facility is a monetary market infrastructure which permits multilateral buying and selling of DLT securities on knowledgeable foundation. These book-entry securities are transferred and held on a blockchain-based platform.
DLT Buying and selling Services are required to a minimum of admit authorized entities apart from supervised monetary establishments or personal purchasers as contributors; present central custody of DLT securities underneath uniform guidelines and procedures; or provide clearing and settlement for DLT securities.
Licensing of those amenities relies on the DLT Act, which entered into power in Switzerland in August 2021 and created a brand new sort of economic market infrastructure.
As a part of the licensing course of, FINMA requires candidates to deal with enterprise continuity, together with settlement infrastructure on public blockchains. To restrict operational dangers, licensees are required to hold out technical checks of the know-how used, corresponding to checking the supply code utilized by good contracts. Sturdy threat administration and management methods are additionally necessary.
Minimal capital necessities embrace CHF 1 million for DLT Buying and selling Services with out central custody or clearing and settlement providers; or CHF 5 million for DLT buying and selling amenities offering these providers. Small DLT Buying and selling Services should maintain a minimum of CHF 500,000 or 5% of all DLT securities in custody.
Cost Methods
For firms working cost methods, FINMA authorization is barely required if essential for the correct functioning of the monetary market or the safety of economic market contributors, and if the cost system isn’t operated by a financial institution.
Candidates will need to have a minimum of at CHF 1.5 million in minimal capital and supply collateral. Governance necessities mirror these of Fintech Licensees, and embrace confirmed integrity of certified contributors and administration; clear separation between administration, oversight, and inner audit features; a supervisory physique with a minimum of three members; efficient threat administration and inner management methods, plus an impartial inner audit operate; and a acknowledged regulatory audit agency should even be appointed for ongoing supervision.
Present License Holders
So far, FINMA has licensed one DLT Buying and selling Facility, specifically BX Digital, which makes use of the Ethereum blockchain to commerce and settle DLT securities, and 5 fintech firms.
Yapeal is a Swiss app-based financial institution which mixes a personal account with a Visa Debit card. It additionally gives embedded finance by way of a B2B2X mannequin, claiming over 850 company purchasers, and partnering with 25 Swiss companies to combine its monetary providers.
Bivial, previously referred to as Klarpay, gives multi-currency accounts, cost providers, and acceptance, serving each people and companies. Since commencing operations, Bivial has remained persistently worthwhile, doubling its annual revenue in 2024 in comparison with the earlier yr. It now serves almost 500 company purchasers.
Fiat24, operated by SR Saphirstein, is a world cost app leveraging blockchain know-how to offer purchasers entry to a Swiss IBAN account of their title, a Visa debit card, overseas alternate (FX), and extra; and Relio is a digital Swiss checking account for small and medium-sized enterprises (SMEs).
Lastly, Swiss4, as soon as a digital banking startup with roughly 250 prospects, is presently in liquidation. FINMA opened chapter proceedings in opposition to the fintech establishment on March 4, 2025, citing over-indebtedness and extreme liquidity points.
Featured picture: Edited by Fintech Information Switzerland, primarily based on pictures by jofreepik and creativeart through Freepik