International consultancy EY has launched a brand new licensing information for market contributors in Switzerland, providing sensible steering for trade gamers together with fintech companies, distributed ledger know-how (DLT) buying and selling platforms, and fee system operators.
It supplies an outline of the principle sorts 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 exterior 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 just accept public deposits with out participating in conventional banking actions similar 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 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. In contrast, 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 corporations, partnerships with limitless companions, and restricted legal responsibility corporations, and minimal capital should equal at the very least 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 embrace administration positioned in Switzerland, at the very least 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 programs protecting market, credit score, default, settlement, liquidity, picture, operational and authorized dangers. They have to keep clear separation of inner capabilities, particularly lending, buying and selling, asset administration and settlement, and have an impartial 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 stability sheet complete, and 80% primarily based on the corporate’s gross earnings.
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, particularly these working digital asset buying and selling platforms and fee programs.
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 an expert foundation. These book-entry securities are transferred and held on a blockchain-based platform.
DLT Buying and selling Services are required to at the very least 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 supply clearing and settlement for DLT securities.
Licensing of those services relies on the DLT Act, which entered into power in Switzerland in August 2021 and created a brand new sort of monetary 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, similar to checking the supply code utilized by good contracts. Strong threat administration and management programs are additionally obligatory.
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 services offering these providers. Small DLT Buying and selling Services should maintain at the very least CHF 500,000 or 5% of all DLT securities in custody.
Cost Methods
For corporations working fee programs, FINMA authorization is simply required if mandatory for the right functioning of the monetary market or the safety of monetary market contributors, and if the fee system shouldn’t be operated by a financial institution.
Candidates will need to have at the very least 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 capabilities; a supervisory physique with at the very least three members; efficient threat administration and inner management programs, 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 corporations.
Yapeal is a Swiss app-based financial institution which mixes a personal account with a Visa Debit card. It additionally presents 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 generally known as Klarpay, supplies multi-currency accounts, fee 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 worldwide fee app leveraging blockchain know-how to provide 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 at the moment in liquidation. FINMA opened chapter proceedings in opposition to the fintech establishment on March 4, 2025, citing over-indebtedness and extreme liquidity points.
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Featured picture: Edited by Fintech Information Switzerland, primarily based on photos by jofreepik and creativeart through Freepik
