Crypto license in Switzerland
FinTech capital
Капитал финтеха
CHF 300,000 or 3%
300 000 CHF или 3%
Deposits ceiling
Потолок депозитов
CHF 100 million
100 млн CHF
Banking licence
Банковская лицензия
CHF 10 million
10 млн CHF
FINMA hourly rate
Ставка FINMA в час
CHF 100–500
100–500 CHF
When Switzerland needs you licensed at all
You exchange or transfer coins
Trading virtual currencies, running a payment system or keeping wallets for others makes you a financial intermediary under the money laundering statute.
Client money lands in your accounts
Once customer funds reach accounts in your own name, the question stops being about money laundering and becomes a question about deposits.
You hold coins for twenty-plus clients
Above twenty clients, or once you advertise that you accept assets, the regulator treats the activity as commercial and a banking authorisation appears.
Each client keeps a separate address
The regulator says plainly that storing every client's assets on individual blockchain addresses keeps you out of the banking rules.
You run a venue for tokenised securities
Multilateral trading in tokenised securities is its own authorisation, and the thresholds that trigger it are written in the market infrastructure ordinance.
What you get
- A settled category and a named supervisor
- Affiliation with a recognised self-regulatory body
- Capital and audit arrangements that fit the route
- Custody rules the ordinance actually imposes
- Threshold monitoring after you launch
Swiss crypto authorisation, category by category
What the money looks like on each route
| Route | Capital or fee |
|---|---|
| Affiliation with a self-regulatory body | no statutory capital floor |
| FinTech authorisation, article 1b | 3% of deposits, min CHF 300,000 |
| Deposits ceiling on that authorisation | CHF 100 million |
| Banking licence, new bank | CHF 10 million paid up |
| Securities firm | CHF 1.5 million paid up |
| Trading venue for tokenised securities | CHF 1 million, or 5 million with settlement |
| Regulator's fee, bank or securities firm | CHF 10,000–100,000 |
| Hourly rate where no flat fee exists | CHF 100–500 |
| Annual supervisory levy, bank | CHF 15,000 |
Rules for crypto you hold for others
- Assets taken into collective custody have to be kept in Switzerland, and in the same form in which they were received.
- They are held separately from the firm's own funds, or booked so they can be shown separately at any moment, which brings a full statutory audit with it.
- Deposits under the FinTech authorisation are neither invested nor paid interest on, and clients must be told in writing before they deposit.
- Those deposits carry no depositor protection and no immediate payout, and the client has to know that in advance.
- Crossing CHF 100 million means telling the regulator within ten days and filing for a banking licence within ninety.
- Compliance and risk management have to be independent of the revenue side inside the firm, though a smaller business with gross income below CHF 1.5 million can ask the regulator to relax that.
The wider country picture sits on our Switzerland page.
Four answers, and your activity picks one
Self-regulatory body under the money laundering statute
Anyone professionally accepting, holding or helping to transfer third-party assets must join a recognised organisation, which supervises compliance instead of the regulator.
FinTech authorisation under article 1b
For firms taking public deposits up to CHF 100 million, or crypto assets in collective custody, provided nothing is invested and no interest is paid.
Full banking licence
Once deposits are invested, earn interest or pass the ceiling, the banking regime applies with its ten million in paid-up capital.
Trading venue for tokenised securities
A separate authorisation for multilateral trading in digital securities, priced by whether the venue also settles and holds them.
Sources: Banking Act, art. 1b and 3 (SR 952.0); Banking Ordinance, art. 14f, 15 and 17a (SR 952.02); Anti-Money Laundering Act, art. 2, 12 and 14 (SR 955.0); Financial Market Infrastructure Ordinance, art. 13 (SR 958.11); FINMA Fees and Charges Ordinance, art. 8 and Annex (SR 956.122); finma.ch, FinTech section.
Stages of work
Classify what you actually do
We map every service against the statutory definitions: accepting third-party assets, transferring them, holding keys, issuing tokens or matching orders. That mapping fixes the route.
Test the deposit question first
Whether client assets are deposits decides everything downstream, and the answer turns on individual addresses, client numbers, advertising and whether anything is invested.
Choose and approach a supervisor
On the money laundering route we approach a recognised self-regulatory organisation; on the others the file goes to the regulator itself.
Build the compliance file
Internal rules, business scope, organisation, risk management and controls are written to the standard the chosen supervisor applies before it will take you.
Capital, custody and audit
Capital is paid in and kept paid in, custody arrangements are set up in Switzerland, and an approved audit firm is engaged where the route requires one.
Application and questions
The submission goes in, and where the published annex fixes no rate for the procedure the regulator bills by time spent, at its own hourly rate and with a surcharge for urgent work.
Watch the thresholds afterwards
Deposit volume, client numbers and trading value are monitored, because crossing a line starts a ten-day notification clock.
Our case studies
FAQ
Discuss
the Task
Speak to our team
Speak to our team. Tell us about your task –
we’ll help you with it in any jurisdiction.