Switzerland fintech licence.

What you get

How we get you licensed and live

1. Scoping and proposal. We confirm whether you need the fintech licence or SRO affiliation, your deposit position against the exemptions, the capital and the three-scenario budget FINMA expects.
2. Application pack. The business plan, three-year budget and monthly liquidity plan, the organisation chart, the risk, compliance and ICT documentation and the manager and major shareholder files with extracts under three months old for FINMA.
3. Banking. The sight deposit account for client deposits, which is a licence condition, and your operating accounts, opened alongside the application.
4. Regulator engagement. We answer every FINMA question and support any licensing audit report it orders, through to the decision; operations start only once the licence is granted.

Your team, banking and technology

You will need managers living close enough to run the business from Switzerland, and a board of at least three, one third independent of management.

One programme, from scoping to launch. Speak to an expert about this licence.

Who needs the licence

A company that holds customer balances in Switzerland, such as a payment account, wallet or prepaid provider, accepts public deposits and needs a licence once the balances exceed the Banking Ordinance exemptions: settlement balances cleared within 60 days, small prepaid balances for future purchases of up to CHF 3,000 per person, and the CHF 1 million sandbox. The fintech licence covers deposits up to CHF 100 million without lending or interest; above that, or where deposits are invested or interest is paid, a banking licence applies. A payment business that moves money without holding deposits joins a self-regulatory organisation instead.

The three tiers

What FINMA requires

• Legal form and location. An AG, Kommandit-AG or GmbH with its seat and actual management in Switzerland; effective management from Switzerland, with managers resident where they can run the business.
• Governance. A precise business scope and a suitable management organisation; where a governing body is required, at least three members with at least one third independent of management; shareholders of 10% or more of good repute; risk management, internal control and compliance functions independent of revenue-generating units and documented in writing, with relief available below CHF 1.5 million of gross income for a low-risk model.
• Capital and financial planning. Minimum capital of 3% of public deposits and at least CHF 300,000, fully paid in and not lent to major shareholders or related persons; a three-year budget under optimistic, realistic and pessimistic scenarios, a monthly year-one liquidity plan under the pessimistic case, and a demonstration of how the capital keeps pace as deposits grow.
• Custody of deposits. Deposits and custodied crypto-assets held separately from own funds, or recorded so they can be shown separately at any time; deposits held as sight deposits at a bank or as Category 1 high-quality liquid assets; crypto-assets held in Switzerland in the form received. There is no deposit insurance and no privileged-deposit treatment, and clients are told so in writing before depositing.
• Audit and changes. Accounts under the Code of Obligations, audited annually, with a regulatory audit by an audit firm approved by the Federal Audit Oversight Authority; prior FINMA approval for changes to key documents, major shareholders (10% or more), management, organisation, activities, outsourcing of core services and foreign activities.
• Application pack. In an official language or English, with the articles and regulations in an official language: commercial register and debt extracts, group chart, business plan and budget, liquidity plan, organisation chart with full-time equivalents, risk, compliance and ICT documentation, outsourcing contracts, any crypto custody description and the audit firm’s acceptance; for each manager and major shareholder, identity documents, a residence permit for foreign nationals, criminal and debt-collection extracts under three months old, a signed CV with two references and the FINMA forms. FINMA may order a licensing audit report at the applicant’s cost. Operations start only once the licence is granted.

Capital

FINMA’s guidelines require the budget under optimistic, realistic and pessimistic scenarios and a monthly liquidity plan for the first year under the pessimistic case.

Timing

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.

Fees and costs

The SRO route for payment services

A payment business that transmits money or value, issues means of payment such as cards or prepaid e-money, or operates a payment system, without holding public deposits beyond the Banking Ordinance exemptions, is a financial intermediary under Article 2 of the Anti-Money Laundering Act. It joins a FINMA-recognised self-regulatory organisation (SRO), which supervises it for anti-money laundering purposes; FINMA itself issues no licence. The activity is professional above CHF 50,000 of gross revenue a year, more than 20 contracting parties, assets under control above CHF 5 million or transaction volume above CHF 2 million a year, and money or value transfer is professional whatever its scale.

Figures are from the VQF fee regulations in force from 1 January 2026, excluding VAT. Admission runs from submission of documents and payment, through a completeness check and a legal and compliance review, to an admission interview and written confirmation. SRO affiliation does not permit holding public deposits: settlement balances cleared within 60 days, small prepaid balances and the CHF 1 million sandbox are the limits, and beyond them the fintech or banking licence applies.

Geographic scope

The licence covers Switzerland only and carries no EU or EEA passport. The business is conducted in Switzerland; cross-border activity is a change requiring FINMA’s approval and documentation of the cross-border risk. Groups serving the EU hold a separate EU authorisation, which we obtain alongside.

Why applications are delayed

FINMA states that processing time depends on the complexity of the project and on the quality and completeness of the application, and reports that a relatively large share of applications did not qualify for a licence: about 30 applications since 2019 and 7 licences by the end of 2025, with 4 of those companies still operating. We plan around FINMA’s own requirements.

1. The project. A precise business scope, a budget under three scenarios and a liquidity plan, and a demonstration that capital keeps pace with deposits.
2. The organisation. Risk, compliance and internal control independent of the revenue side, documented, and managers resident where they can run the business.
3. Good repute. Complete files on every manager and major shareholder, with extracts under three months old.

FINMA notes in its 2025 report a planned payment instrument institution licence intended to replace Article 1b; we track the proposal and advise on timing.

Banking

A fintech licensee holds client deposits as sight deposits at a bank or in Category 1 high-quality liquid assets, so a Swiss bank account is a licence condition. We open the deposit account and the operating accounts alongside the application, so you trade once licensed. See banking and payment processing.

Common questions

References

1. FINMA: fintech licence
2. FINMA: guidelines for fintech licence applications, 24 April 2025
3. Banking Act (SR 952.0), Article 1b
4. Banking Ordinance (SR 952.02), Articles 6, 7a, 14a to 14g and 17a
5. FINMA Fees and Levies Ordinance (SR 956.122), Articles 8, 19e and 19f
6. FINMA annual report 2025

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.