FINMA Crypto Licence 2026: How to Get a Swiss Crypto Licence

Which FINMA Licence Do You Need for Crypto Activities?

Any company that accepts public deposits through crypto tokens, operates a crypto exchange or marketplace, manages digital assets on behalf of clients, or runs a DLT-based trading facility in Switzerland requires a FINMA licence. The specific licence depends on the business model: a fintech licence under BankG Art. 1b for deposit-taking up to CHF 100’000’000, a full banking licence under the Banking Act for unlimited deposits, a securities firm or asset management licence under FINIG for managing crypto funds, or a DLT trading system licence under FinfraG Art. 73a-73g for operating a decentralised exchange.

Switzerland was among the first jurisdictions to create a regulatory framework specifically for blockchain and distributed ledger technology. The Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology (DLT Act), which entered into force in stages between 1 February 2021 and 1 August 2021, amended existing financial market laws rather than creating an entirely new regime. This means crypto businesses must fit into one of the established FINMA licence categories — there is no standalone “crypto licence” as such.

FINMA itself does not distinguish between crypto-specific and traditional financial services. A company dealing in crypto assets is subject to the same prudential and anti-money laundering standards as any other supervised entity. What differs is how each business model maps onto the existing licence types. Below we set out the four main licence categories, their legal bases, requirements, and the practical steps to obtain each one.

Four FINMA Licence Types for Crypto Businesses

The following table summarises the main licence categories available to crypto companies in Switzerland, their legal basis, and the activities they cover.

Some activities do not require a licence at all. Pure software development, blockchain consulting, or mining without accepting third-party funds fall outside FINMA’s supervisory perimeter. However, any activity that involves holding or transmitting client assets triggers at minimum an affiliation with a self-regulatory organisation (SRO) under the Anti-Money Laundering Act (GwG).

Fintech Licence (BankG Art. 1b)

The fintech licence was introduced on 1 January 2019 as a lower-threshold alternative to the full banking licence. It permits a company to accept public deposits of up to CHF 100’000’000, provided those deposits are neither invested nor interest-bearing. For crypto businesses, this licence covers custodial wallet services, stablecoin issuance within the deposit cap, and payment token platforms.

Requirements for the fintech licence:

• Minimum capital: CHF 300’000 fully paid-in share capital
• Deposit cap: CHF 100’000’000 in total public deposits at any time
• No investment: deposits must not be invested and must not bear interest
• Organisation: adequate risk management, internal controls and compliance function
• AML compliance: affiliation with a FINMA-recognised SRO or direct FINMA supervision under GwG
• Auditor: appointment of a FINMA-recognised audit firm
• Substance: effective management from Switzerland; at least two qualified persons directing the business from a Swiss office

The fintech licence is substantially simpler than a full banking licence. There is no requirement for deposit insurance (Einlagensicherung), no liquidity ratio obligations, and no requirement for a full-scale internal audit department. Processing times at FINMA are typically shorter — between 3 and 6 months from submission of a complete application.

Companies that start small and later exceed the CHF 100’000’000 deposit threshold must upgrade to a full banking licence. FINMA expects a transition plan to be in place before the cap is reached.

Banking Licence (Full BankG Compliance)

A full banking licence under BankG Art. 3-4 is required for any crypto business that accepts public deposits without a cap, offers interest on crypto deposits, or lends against crypto collateral. Several Swiss entities — including Sygnum, SEBA (now AMINA) and Maerki Baumann — hold full banking licences and offer crypto services alongside traditional banking.

Requirements for the banking licence:

• Minimum capital: CHF 10’000’000 fully paid-in (higher for systemically important institutions)
• Capital adequacy: compliance with the Capital Adequacy Ordinance (ERV), including risk-weighted capital ratios under Basel III
• Liquidity: compliance with the Liquidity Ordinance (LiqV), including Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR)
• Deposit insurance: membership in esisuisse, the Swiss deposit insurance scheme (coverage up to CHF 100’000 per depositor)
• Governance: board of directors with banking experience, independent risk committee, internal audit function, compliance officer, Chief Risk Officer
• AML compliance: direct FINMA supervision under the Anti-Money Laundering Act (GwG Art. 2-9), including transaction monitoring, KYC and suspicious activity reporting to MROS
• Auditor: FINMA-recognised bank audit firm
• Business plan: three-year projections, capital planning, stress testing

The application process for a full banking licence typically takes 6-12 months. FINMA conducts a thorough review of the applicants’ organisational structure, IT infrastructure, risk management framework, and the fitness and propriety of all qualified participants (holders of 10% or more of voting rights).

For a crypto company in Switzerland planning to accept large-scale deposits or offer lending, the banking licence is the only viable path.

DLT Trading System Licence (FinfraG Art. 73a-73g)

The DLT trading system licence is Switzerland’s most distinctive regulatory innovation for crypto. Introduced by the DLT Act on 1 August 2021, it created a new category of financial market infrastructure under the Financial Market Infrastructure Act (FinfraG). A DLT trading system can admit not only regulated financial intermediaries but also retail participants directly — a feature unavailable to traditional stock exchanges.

A DLT trading system is authorised to:

• List and trade DLT securities (Registerwertrechte as defined in the Swiss Code of Obligations, OR Art. 973d-973i)
• Provide central custody, clearing and settlement of DLT securities on the distributed ledger itself
• Admit non-regulated participants (retail investors), subject to transaction limits set by FINMA

Requirements specific to the DLT trading system licence:

• Minimum capital: CHF 1’000’000 (lower than a traditional exchange, which requires CHF 10’000’000)
• Organisation: adequate governance, risk management, and operational resilience, including cyber security and business continuity plans
• Participant rules: clear admission criteria, trading rules, and conflict-of-interest management
• Transparency: pre-trade and post-trade transparency requirements comparable to those for traditional trading venues
• AML: full GwG compliance; each participant must be identified and verified

As of 2026, SDX (SIX Digital Exchange) operates a DLT trading system under this licence. Other applicants are at various stages of the FINMA approval process. The licence is well suited for platforms tokenising equities, bonds, fund units, or structured products as DLT securities.

Asset Management Licence for Crypto Funds (FINIG and KAG)

Managing crypto assets on behalf of clients — whether through a collective investment scheme or discretionary mandates — requires a licence under the Financial Institutions Act (FINIG) and, for fund management, the Collective Investment Schemes Act (KAG).

The two main licence types are:

• Asset manager of collective investment schemes (FINIG Art. 5-19): required for managing a Swiss or foreign fund that invests in crypto assets. Minimum capital: CHF 200’000 or one-quarter of fixed costs (whichever is higher)
• Fund management company (KAG Art. 28 et seq.): required for a Swiss fund management company that creates and administers Swiss-domiciled collective investment schemes. Minimum capital: CHF 1’000’000

Individual portfolio managers who manage crypto portfolios on a discretionary basis for individual clients must register as portfolio managers under FINIG Art. 17-19 and affiliate with a FINMA-approved supervisory organisation (SO).

The key challenge for crypto fund managers is the classification of crypto assets for regulatory capital and risk management purposes. FINMA Guidance 02/2019 treats most payment tokens and utility tokens as assets eligible for collective investment schemes, provided proper valuation, custody, and risk disclosure standards are met.

For firms looking to set up a fintech operation in Switzerland, the asset management licence provides a route to offer managed crypto products to qualified and institutional investors.

Fit and Proper Requirements for Crypto Licence Applicants

Every FINMA licence application is assessed against fit and proper (Gewahr) criteria. These apply to all persons who direct, manage, or control the applicant — including board members, executive management, and qualified participants holding 10% or more of voting rights.

FINMA evaluates:

• Professional qualifications: relevant education and experience in financial services, technology, or law. For a crypto business, FINMA expects at least one board member and one executive with demonstrable experience in digital assets or financial market infrastructure
• Reputation: no criminal convictions for financial offences, no pending enforcement proceedings, no history of regulatory sanctions in Switzerland or abroad
• Financial soundness: qualified participants must demonstrate the financial capacity to support the applicant and must not pose a risk to prudent business conduct
• Independence: the board must include members independent of management and significant shareholders

AML compliance under GwG Art. 2-9 is a prerequisite for all licence types. The applicant must demonstrate:

• A documented AML/CFT framework, including customer due diligence (CDD), enhanced due diligence (EDD) for higher-risk clients, and ongoing monitoring
• Appointment of a qualified AML compliance officer
• Registration with the Money Laundering Reporting Office (MROS) for suspicious activity reports
• Compliance with FINMA’s AML Ordinance (GwV-FINMA) and, where applicable, the FATF Travel Rule for virtual asset transfers

FINMA may reject an application or impose conditions if any person in a key function fails the fit and proper assessment. In practice, assembling a qualified board and executive team is one of the most time-consuming steps in the application process.

Minimum Capital and Substance Requirements

Each licence type carries a different minimum capital threshold. The table below summarises the requirements as of 2026:

Beyond capital, FINMA requires genuine substance in Switzerland. This means:

• Physical office: a real office address (not a virtual office for regulated entities), with IT infrastructure, secure document storage, and meeting facilities
• Effective management: at least two persons (four eyes principle) must direct the business from Switzerland. They must reside in Switzerland or in a neighbouring country with daily commuting distance
• Operational independence: the Swiss entity must not be a mere letterbox. Key decisions — risk management, compliance, client onboarding — must be taken locally
• IT and cyber security: FINMA Circular 2023/1 on operational risks requires documented IT governance, penetration testing, incident response plans, and business continuity arrangements

Goldblum und Partner AG at Baarerstrasse 25 in Zug assists with corporate structuring, board composition, and substance arrangements to meet FINMA’s expectations from the outset.

Application Timeline and FINMA Fees

The FINMA licensing process follows a structured sequence. While timelines vary by licence type and application quality, the following is a realistic estimate for 2026:

• Pre-application phase (1-3 months): informal discussions with FINMA, often through a “pre-consultation” (Vorabklärung). FINMA encourages applicants to present their business model before filing. This step is not mandatory but significantly reduces the risk of rejection
• Application preparation (2-4 months): drafting the complete dossier — business plan, organisational chart, governance documents, AML framework, IT security concept, capital and liquidity projections, fit and proper documentation for all key persons
• FINMA review (3-6 months): FINMA reviews the application, requests clarifications or additional documents, and conducts on-site visits if needed. For a banking licence, the review may extend to 9-12 months
• Decision: FINMA grants the licence, grants it with conditions, or rejects the application. Conditional approvals often require specific measures (e.g., additional capital, governance improvements) before commencing operations

Total timeline from first contact to licence grant:

• Fintech licence: 6-9 months
• Banking licence: 9-18 months
• DLT trading system: 6-12 months
• Asset management licence: 4-8 months

FINMA charges cost-covering fees for licence applications. As a guide:

• Fintech licence application: CHF 20’000-50’000
• Banking licence application: CHF 50’000-200’000
• DLT trading system application: CHF 30’000-100’000
• Asset management licence: CHF 10’000-30’000

These are FINMA’s own fees only. Legal, compliance, and consulting costs for preparing the application typically add CHF 100’000-500’000 depending on the complexity of the business model and the licence type. Annual supervisory fees are charged separately once the licence is granted.

Crypto Valley Zug: Switzerland’s Blockchain Ecosystem

Zug has been the centre of Switzerland’s crypto and blockchain ecosystem since the Ethereum Foundation established its headquarters there in 2014. The term “Crypto Valley” — coined in 2013 — now refers to an area spanning Zug, Zurich, and neighbouring cantons that hosts over 1’100 blockchain companies and 6’000 employees.

Practical advantages of Zug for crypto licence applicants:

• Regulatory familiarity: the Zug commercial register office and cantonal authorities have processed hundreds of blockchain-related incorporations and are experienced with token-based business models
• Talent pool: proximity to ETH Zurich, University of Zurich, and the Crypto Valley Association provides access to blockchain engineers, compliance specialists, and financial structuring expertise
• Tax efficiency: Zug offers the lowest combined corporate tax rate in Switzerland at 11.85%, with additional reductions available through the patent box and R&D super-deduction
• Network effects: established crypto banks (Sygnum, AMINA), custodians (Taurus, Metaco), and legal firms specialising in DLT regulation operate from Zug
• International connectivity: Zurich Airport is 30 minutes from Zug; the Zug-Zurich economic corridor offers office space at lower rents than central Zurich

For companies forming a Swiss company with the goal of obtaining a FINMA licence, Zug provides a combination of regulatory efficiency, industry infrastructure, and fiscal competitiveness that no other Swiss location matches.

For an overview of how to open a banking relationship alongside your licensed entity, see our guide on Swiss bank accounts.