World consultancy EY has launched a brand new licensing information for market individuals in Switzerland, providing sensible steering for business gamers together with fintech corporations, distributed ledger know-how (DLT) buying and selling platforms, and cost system operators.
It offers an summary of the primary 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 beneath 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 corporations, BA is the core regulation. Underneath this regulation, the Fintech License permits corporations to simply accept public deposits with out partaking in conventional banking actions akin to lending or paying curiosity. Launched in January 2019, it presents a decrease regulatory burden than a full banking license, whereas nonetheless requiring compliance with anti–cash laundering guidelines and sturdy danger administration.
The license permits holders to simply accept as much as CHF 100 million in public deposits or crypto-assets, with out investing or paying curiosity on them. In contrast, a conventional 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 embody restricted corporations, partnerships with limitless companions, and restricted legal responsibility corporations, 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, totally paid up and maintained always.
Governance necessities embody administration positioned in Switzerland, a minimum of a 3rd of the governing physique unbiased of administration, and assurance of irreproachable enterprise conduct by key individuals and administration.
Licensees should additionally implement efficient danger administration methods overlaying market, credit score, default, settlement, liquidity, picture, operational and authorized dangers. They have to keep clear separation of inner capabilities, specifically lending, buying and selling, asset administration and settlement, and have an unbiased inner audit operate. They have 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 steadiness sheet complete, and 80% primarily based on the corporate’s gross revenue.
On prime of those levies, corporations should additionally pay for related monetary and regulatory audits, payable to the respective audit corporations. FINMA estimates this quantity to be round CHF 40,000 to CHF 50,000, which is considerably lower than what’s due for a daily banking license.
DLT Buying and selling Services
Along with BA, FinMIA is one other key regulation for fintech corporations, specifically 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 allows 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 aside from supervised monetary establishments or non-public shoppers as individuals; present central custody of DLT securities beneath uniform guidelines and procedures; or provide clearing and settlement for DLT securities.
Licensing of those services relies on the DLT Act, which entered into pressure 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 handle 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, akin to checking the supply code utilized by good contracts. Strong danger administration and management methods are additionally necessary.
Minimal capital necessities embody 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 services 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.
Fee Methods
For corporations working cost methods, FINMA authorization is barely required if mandatory for the correct functioning of the monetary market or the safety of economic market individuals, 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 embody confirmed integrity of certified individuals and administration; clear separation between administration, oversight, and inner audit capabilities; a supervisory physique with a minimum of three members; efficient danger administration and inner management methods, plus an unbiased 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, particularly BX Digital, which makes use of the Ethereum blockchain to commerce and settle DLT securities, and 5 fintech corporations.
Yapeal is a Swiss app-based financial institution which mixes a non-public account with a Visa Debit card. It additionally presents embedded finance by means of a B2B2X mannequin, claiming over 850 company shoppers, and partnering with 25 Swiss companies to combine its monetary providers.
Bivial, previously often known as Klarpay, offers multi-currency accounts, cost providers, and acceptance, serving each people and companies. Since commencing operations, Bivial has remained constantly worthwhile, doubling its annual revenue in 2024 in comparison with the earlier 12 months. It now serves almost 500 company shoppers.
Fiat24, operated by SR Saphirstein, is a world cost app leveraging blockchain know-how to present shoppers 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 clients, 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 photographs by jofreepik and creativeart by way of Freepik
