FINMA Licence in Switzerland
A FINMA-licensed Swiss company gives you regulated access to Switzerland’s financial system under banking-type supervision, not a marketing label. For most fintech and crypto models, a fresh FinTech licence under Art. 1b of the Banking Act means 9–18 months of preparation, review, and implementation before you can operate. A ready-made FINMA-regulated company lets you focus on business and client onboarding once FINMA approves you as the new qualified shareholder.
This structure is attractive, but it is not a shortcut around regulation. You still need transparent ownership, a business model that fits Swiss rules, capital in at least the low seven-figure range, and a board and management capable of running a supervised institution from Switzerland. The licence allows up to CHF 100 million in non-interest-bearing client funds, yet it does not make the firm a full bank, and client money is outside the Swiss deposit protection scheme.
On this page we explain how a ready-made FINMA licence in Switzerland works in practice, with a focus on the FinTech licence and related FinIA categories. We show what the licence actually permits, what FINMA expects from new controllers, and in which cases this route is more realistic than applying from scratch. Our aim is simple: within a few minutes, you should know whether a FINMA-regulated Swiss vehicle fits your product, your budget, and your risk appetite.
Table of Contents
Subtype
FINMA
Jurisdiction
Switzerland
Category
Investment
Type
Business Licenses
Key Takeaways for FINMA Licence in Switzerland
- A FINMA FinTech licence under Art. 1b Banking Act lets a Swiss institution hold up to CHF 100 million in non-interest-bearing client funds or crypto assets, enabling payment accounts and custody but not lending, securities dealing, or asset management without extra FinIA licences.
- The licence requires a Swiss AG or GmbH with real Swiss presence, Swiss-based management, and owners approved as qualified shareholders from 10 percent, with further FINMA review when stakes cross 20, 33, and 50 percent.
- Regulatory capital must be at least 3 percent of client funds with a hard minimum of CHF 300,000, while realistic projects usually need capital from about CHF 1 million and annual running costs of roughly CHF 300,000–700,000 for staff, office, IT, audit, and compliance.
- Ongoing duties include strict AML and KYC under AMLA and AMLO-FINMA, annual financial and regulatory audits, reporting to MROS, outsourcing controls under FINMA Circular 2018/3, and full tax and accounting at combined Swiss corporate income tax rates of about 11.9–20.5 percent depending on canton.
- A FINMA licence in Switzerland brings strong credibility but no EU passporting or automatic US access, and Swiss banks remain selective, so many firms combine Swiss accounts with foreign EMI or PSP solutions to manage crypto-heavy or cross-border flows.
- Legasset can help you buy a ready-made FINMA-licensed Swiss company or apply for a new licence from scratch, covering structuring, cost and capital planning, policy and governance design, FINMA applications and change-of-control files, plus ongoing support with audits, reporting, and banking strategy.
What You Need to Know About the FINMA Licence in Switzerland
A FINMA-licensed Swiss company under Art. 1b of the Banking Act is a banking type institution with lighter prudential rules. It may hold up to CHF 100 million in client deposits or crypto based assets, as long as these funds are not invested and do not earn interest.
This licence suits payment platforms, wallet providers, card programmes, and crypto businesses that need Swiss client accounts under direct supervision. Typical models include fiat on ramp and off ramp services, multi currency payment accounts, and custodial wallets with API access for partners. The licence does not allow commercial lending, proprietary trading, or asset management, unless the firm also holds the relevant FinIA licences.
There are important constraints. Client money is outside the Swiss depositor protection scheme, so risk wording in contracts and on boarding flows is essential. Management and key staff must be based in Switzerland, and any buyer of a ready made institution needs FINMA approval as a qualified shareholder. In 2025 the licence is particularly relevant because collective custody of payment tokens increasingly falls inside the banking perimeter, and the planned Payment Institution and Crypto Asset Service Provider categories will build on this supervised model rather than replace it.
Regulatory and tax framework for a FINMA licence in Switzerland
The licence is granted by the Swiss Financial Market Supervisory Authority (FINMA). FINMA applies the Banking Act and Banking Ordinance, AML duties under AMLA and AMLO FINMA, conduct rules under FinSA, and organisational requirements under FinIA where the business also manages assets. Outsourcing and IT are covered by FINMA Circular 2018/3 Outsourcing, while the Swiss DLT Act defines how tokenised assets and payment tokens are held in custody.
Swiss companies pay combined federal and cantonal corporate income tax, usually between 11.9% and 20.5% depending on canton and real substance. There is no special reduced rate for FinTech licence holders, so planning often focuses on canton choice and a realistic long term cost base for compliance, audit, and staff.
Clients can either purchase a ready made FINMA licensed Swiss company or apply for a new licence. Our team assists with both options by mapping the business model to Swiss rules, preparing ownership and governance changes, and setting up the compliance framework so the licence can be used safely in daily operations.
Eligibility Requirements for Obtaining a FINMA Licence in Switzerland
A FINMA licensed institution must be a Swiss AG or GmbH or a partnership limited by shares. The registered office and effective management must be located in Switzerland, with board meetings and key decisions taken in the country. FINMA checks that directors and senior managers are reliable, experienced in financial services, and able to run the institution on a day to day basis.
Any person holding a qualified participation of 10 percent or more in capital or votes must be disclosed. Crossings of 10, 20, 33, or 50 percent require prior notification and, in practice, prior comfort from FINMA. Buyers of a ready made FINMA company are assessed on the same tests, including source of funds and ownership structure.
Capital and financial strength
For a FinTech licence under Art. 1b Banking Act, regulatory capital must equal at least 3 percent of client deposits, with a hard minimum of CHF 300,000. In real files FINMA often expects capital from about CHF 1 million upwards, depending on the business model, risk profile, and projected volumes. Capital must be fully paid in, free of debt, and supported by a multi year budget showing that the firm can cover staff, IT, office, audit, and compliance costs.
Ongoing obligations include audited financial statements, regulatory reports, FINMA and audit fees, and Swiss corporate income tax, which usually falls between about 11.9 percent and 20.5 percent depending on canton.
Swiss presence and compliance oversight
The institution must maintain real premises, not only a registered address. Senior management must work from Switzerland and be available for meetings with FINMA and auditors. At least one AML officer and one risk or compliance officer are required, with proven knowledge of AMLA, AMLO FINMA, sanctions rules, and cross border issues that affect the business model.
The firm is subject to reporting duties, including suspicious activity reports to the Swiss MROS, annual audit reports, and notifications of material changes in ownership, organisation, or activities. Outsourced functions must follow FINMA Circular 2018/3, with clear contracts, access rights, and an up to date outsourcing register.
Documentation, timelines, and frequent hurdles
A full application includes constitutional documents, shareholder and UBO declarations, fit and proper forms for directors and managers, a detailed business plan, financial projections, policies for AML and sanctions, risk management, governance, and outsourcing. Many foreign documents need notarisation, apostille, and certified translation into an official Swiss language or English.
From serious preparation to licence activation, a realistic timeframe is 9 to 18 months. Official FINMA fees are only part of the cost; applicants should plan for legal work, audit involvement, internal hiring, and higher banking costs during the build phase. Common problems are underdeveloped crypto or cross border models, owners from higher risk jurisdictions without clear documentation, or staffing plans that do not match the complexity of the activities.
Whether the goal is a new application or the purchase of a ready made FINMA licensed Swiss company, these eligibility criteria apply in full, and careful preparation is the only way to move through the process with a predictable outcome.
Pros & Cons of Acquiring a FINMA Licence in Switzerland
+ Banking-type supervision under Swiss law. The licence is granted under Art. 1b of the Banking Act, which places the institution within a recognised prudential framework. This helps when approaching counterparties that require direct oversight rather than SRO membership alone.
+ Permission to hold up to CHF 100m. The ability to keep up to CHF 100 million in non-interest-bearing client funds or crypto-based assets enables real account and custody services instead of pure processing models. It is a practical threshold that supports scaling before a full banking licence becomes relevant.
+ Stable regulatory environment. Switzerland applies the Banking Act, FinSA, FinIA, AMLA, and the DLT Act in a predictable way. Once a model is approved, changes usually follow structured consultations rather than abrupt policy shifts seen in some EU states.
+ Credibility with global partners. FINMA-supervised entities are often accepted by institutional clients, trading venues, and PSPs that avoid unsupervised crypto or fintech firms. This can shorten onboarding times and expand available corridors.
+ Competitive tax positioning. Effective corporate income tax between 11.9 percent and 20.5 percent creates room for cost planning, especially compared with higher-tax EU jurisdictions used for financial services.
– No depositor protection and no interest. Client money is outside Switzerland’s depositor protection scheme, so the business must explain this clearly in user documentation. It also limits product design, as interest-bearing features are not allowed.
– Capital expectations exceed the legal minimum. While the law sets the minimum at CHF 300,000, FINMA often expects capital from roughly CHF 1 million upward, supported by multi-year budgets and liquidity planning. Thinly capitalised firms tend to be rejected early in the process.
– Restricted activity set. The FinTech licence does not permit lending, securities trading, or asset management, which means firms must obtain additional FinIA licences if they aim to manage portfolios, run trading desks, or handle collective assets.
– Complex ownership approvals. Any qualified participation of 10 percent or more requires FINMA review. Changes at 10, 20, 33, or 50 percent trigger new checks, and foreign controllers may face extended source-of-funds requests before the transaction can close.
– High operational overhead. Requirements under AMLA, AMLO-FINMA, reporting to MROS, and compliance with FINMA Circular 2018/3 create recurring audit, legal, and staffing expenses. Competitors often omit these costs even though they shape the real budget.
– Challenging banking landscape for crypto activity. Swiss banks remain selective about institutions with significant crypto exposure. Many licensed fintechs still rely on a mix of Swiss accounts and foreign EMI or PSP channels to maintain reliable settlement options.
How to Get a FINMA Licence in Switzerland
You can obtain a FINMA licence either by acquiring a ready made FINMA licensed Swiss company or by applying for a new licence. Both paths require owner approval, Swiss substance, and a full compliance setup. Our team supports each stage, from planning to post approval operations.
Step-by-Step Licensing Process in Switzerland
- Step 1: Scope The Project And Choose The Route 2-4 weeks
You first decide whether a ready made company or a new application fits your timelines and model. An acquisition focuses on change of control approval; a new application focuses on meeting Art. 1b Banking Act and AMLA standards.
Key Documents: business outline, ownership chart, initial capital plan.
Estimated Cost: CHF 15,000-CHF 40,000.
Timeline: 2-4 weeks. - Step 2: Set Up Or Acquire The Swiss Entity 1-2 months
You incorporate a Swiss AG or GmbH or sign a conditional SPA for a ready made entity. Shareholders, directors, and managers must meet fit and proper tests, and capital is paid in at this stage.
Key Documents: articles, UBO forms, director CVs, criminal record extracts, source of funds, SPA if applicable.
Estimated Cost: CHF 30,000-CHF 100,000 plus paid in capital (often from CHF 1,000,000).
Timeline: 1-2 months. - Step 3: Build Governance, Policies, And Capital Plan 2-4 months
You prepare governance, AML and risk policies, outsourcing registers, and a multi year budget. These must comply with AMLA, AMLO-FINMA, FinSA, and FINMA Circular 2018/3.
Key Documents: AML policies, risk policies, outsourcing documentation, IT security plan, 3-5 year budget.
Estimated Cost: CHF 120,000-CHF 300,000.
Timeline: 2-4 months. - Step 4: File The FINMA Application Or Change Of Control Notice 4-9 months
You submit the full FINMA application or a change of qualified shareholder notification. FINMA reviews owners, governance, capital, and the business model.
Key Documents: FINMA forms, full application file, audit report, business plan.
Estimated Cost: CHF 70,000-CHF 200,000.
Timeline: 4-9 months. - Step 5: Respond To FINMA Questions And Implement Conditions 2-4 months
FINMA typically issues several rounds of questions. You revise policies, strengthen staffing, or adjust the model. For acquisitions, closing takes place after FINMA approves the new owner.
Key Documents: written replies, updated policies, revised organisation chart, SPA closing documents.
Estimated Cost: CHF 30,000-CHF 100,000.
Timeline: 2-4 months. - Step 6: Go Live And Maintain Compliance Ongoing
After approval you operate within the authorised scope. Banking onboarding may take time, especially for crypto models, so many firms combine Swiss banking with foreign EMI or PSP channels. Ongoing duties include audits, FINMA reporting, and MROS filings.
Key Documents: client agreements, AML files, audit reports, FINMA periodic reports.
Estimated Cost: CHF 300,000-CHF 700,000 per year.
Timeline: ongoing.
General timeline
- From initial planning to live operations, expect 9-18 months for both ready made and new licence routes, depending on model complexity and FINMA review pace.
Post-Licensing Compliance Obligations for a FINMA Licence in Switzerland
Obtaining a FINMA licence in Switzerland is only the starting point. Licensed institutions must maintain full compliance with the Banking Act, FinSA, FinIA, AMLA, and AMLO-FINMA to stay operational. Failure to meet these requirements can lead to restrictions, enforcement measures, or withdrawal of the licence. As global standards evolve, including FATF guidance and EU developments, firms must reassess their controls regularly to ensure alignment with supervisory expectations.
Key Ongoing Requirements:
- AML/KYC Monitoring: Institutions must update client profiles, apply enhanced due diligence where needed, and conduct continuous transaction monitoring. Suspicious patterns must be reported to the Swiss MROS without delay. This includes screening for sanctions risks and documenting all decisions in the AML file.
- Audits and Regulatory Filings: Every year, firms undergo a full financial and regulatory audit by an approved audit firm. The auditor reports directly to FINMA on governance, risk management, and internal controls. Companies must also file periodic prudential and conduct reports, maintain an accurate outsourcing register under Circular 2018/3, and notify FINMA of material incidents.
- Tax and Accounting Responsibilities: Institutions must prepare annual financial statements, maintain Swiss GAAP compliant accounting records, and file corporate tax returns in their canton. Some models also trigger VAT registration, and crypto-linked revenues may require additional documentation for tax treatment.
- Changes to Business Structure: Any alteration in shareholders or directors that reaches a qualified participation threshold must be reported to FINMA. Changes to the business plan, services, or cross-border footprint may require prior approval and updates to policies and staffing.
- Penalties for Non-Compliance: Weak AML controls, inaccurate reporting, or governance failures can result in fines, special audits, restrictions on activities, or licence withdrawal. FINMA may also impose remedial measures, including appointing an external investigator.
How Legasset Supports Clients
Legasset acts as a long-term partner, assisting clients with AML and governance updates, preparing for annual audits, managing change-of-control filings, and structuring policy revisions in line with FINMA guidance. Our support helps institutions operate safely, maintain their Swiss presence, and stay aligned with regulatory expectations as their business grows.
Common Pitfalls and Challenges of Operating Under a FINMA Licence in Switzerland
A FINMA licence in Switzerland brings strong credibility, but day to day operations are demanding. Firms that underestimate these demands can face delays, higher costs, or closer supervisory attention. With careful planning, these hurdles are manageable, but they must be treated as core business issues, not afterthoughts.
Key Challenges Businesses Face
- Banking and payments: Swiss banks apply strict onboarding, especially for crypto focused models. Opening operating and client accounts can take several months, and many institutions still rely on foreign EMIs or PSPs to cover all payment flows.
- Regulatory changes: Work on new Payment Institution and Crypto Asset Service Provider categories under FinIA, plus pressure on beneficial ownership rules, means that internal policies need regular updates, not just a one off setup.
- Market access limits: A FINMA licence does not give EU passporting or US access. Serving those markets can still require local licences or registrations, which adds time and cost to expansion plans.
- Costly audits and compliance maintenance: Annual audits, Swiss based directors, and dedicated AML and compliance officers create a fixed cost base that easily reaches several hundred thousand francs per year for a live institution.
- Change of control and structure: Any new qualified shareholder from 10 percent must pass FINMA checks. Poorly planned ownership changes or rapid shifts in the business plan can trigger extended reviews or additional conditions.
How Legasset Helps Clients Overcome These Challenges
Legasset helps clients plan banking strategies, test cross border plans against local rules, and budget for real Swiss audit and staffing costs. Our team supports FINMA and audit interactions, prepares change of control files, and updates AML and governance frameworks so that licensed entities can keep operating within Swiss expectations as their business grows.
FAQ About Purchasing a FINMA Licence in Switzerland
How does purchasing a FINMA-licensed Swiss company differ from getting a new FINMA licence in Switzerland?
When you buy a FINMA-licensed Swiss company, you acquire its shares, not the licence itself. FINMA must still approve you as a qualified shareholder (from 10% ownership), while a new application involves licensing a newly formed Swiss AG or GmbH.
How long does it realistically take to start operating with a FINMA licence in Switzerland?
For both a purchase and a new application, you should plan 9–18 months from serious preparation to live operations. This includes company work, FINMA review, follow-up questions, and setting up banking and internal systems.
What ongoing costs should I expect after purchasing a FINMA-licensed Swiss company?
Beyond the purchase price and capital, most institutions spend at least CHF 300,000–700,000 per year on Swiss staff, office, IT, audit, and compliance. These costs arise from AMLA duties, annual audits, and regular FINMA reporting, not just from day-to-day business.
What does a FINMA FinTech licence allow and where are the main limits?
A FinTech licence under Art. 1b Banking Act allows up to CHF 100 million in non-interest-bearing client funds or crypto assets, supporting payment accounts and custody. It does not permit commercial lending, securities dealing, or asset management without additional FinIA licences, and client money is outside Swiss deposit protection.
How can Legasset help with a FINMA licence in Switzerland?
Legasset assists with purchasing a ready-made FINMA-licensed Swiss company or obtaining a new licence from scratch. We help design the model, prepare owner and AML files, manage FINMA change-of-control or licence applications, and coordinate EU structures.
Additional Links and Resources for FINMA Licence in Switzerland
Official FINMA page describing the FinTech licence under Art. 1b Banking Act, including who can apply, permitted activities, capital expectations, and core authorisation requirements for institutions in Switzerland.
II. FINMA – Supervision of Institutions with a FinTech Licence
Explains how FINMA supervises FinTech-licensed institutions in practice, including ongoing reporting, audit interaction, risk-based supervision, and what licence holders can expect after authorisation.
III. FINMA – Legal Basis for Banks and FinTech Institutions
FINMA overview of the main legal acts and ordinances for banks and FinTech institutions, including the Banking Act (BA), Banking Ordinance and related prudential rules that underpin the FinTech licence regime.
IV. Swiss Anti-Money Laundering Act (AMLA)
Federal Act on Combating Money Laundering and Terrorist Financing, setting customer due diligence, transaction monitoring, record-keeping, and reporting duties to MROS for FINMA-supervised financial intermediaries, including FinTech licence holders.
V. FINMA Circular 2018/3 – Outsourcing
FINMA circular setting binding outsourcing requirements for banks, securities firms and selected financial institutions, relevant for structuring IT, cloud, and service-provider setups under a FINMA FinTech licence.
