Swiss FinTech Licence
FinTech licence (BankG Art. 1b).
3% of deposits (min CHF 300K). Up to CHF 100M deposits.
Switzerland's FinTech licence — introduced in 2019 under BankG Art. 1b — permits fintech and crypto businesses to accept public deposits up to CHF 100,000,000 without a full banking licence. No interest on deposits. No investment of deposits. FINMA direct supervision. The correct structure for payment platforms, stablecoin issuers, and digital wallets operating at scale.
3% / CHF 300K
Min capital (higher of)
CHF 100M
Max public deposits
6–12 mo
Application timeline
2019
Licence introduced
FinTech Licence Structure
BankG Art. 1b — key facts
and regulatory limits
FinTech licence (BankG Art. 1b) — specifications
The FinTech licence was introduced by amendment to the Federal Banking Act. In force since 1 January 2019. The first FinTech licence was granted in March 2020 (Yapeal AG).
Minimum capital = the higher of 3% of the public deposits held and CHF 300,000 (BankV Art. 17a). CHF 300,000 is only the floor for a small deposit book; a firm approaching the CHF 100M deposit cap must hold up to ~CHF 3,000,000. Must be paid-in and deposited with a Swiss bank before FINMA application.
The FinTech licence permits acceptance of public deposits up to CHF 100,000,000. Above this threshold, a full banking licence (BankG Art. 1a) is required.
FinTech licence holders may not pay interest on accepted deposits. Any interest-bearing deposit product triggers the requirement for a full banking licence.
Accepted deposits may not be invested. The entity may only hold or transfer funds on behalf of clients — not invest them in assets or lend them out.
FinTech licence holders are directly supervised by FINMA. Annual regulatory reports, ongoing AML programme, and FINMA notification for material changes to business model.
As a FINMA-licensed entity, FinTech licence holders are directly subject to AMLA (GwG). No SRO affiliation required — FINMA supervision replaces SRO membership.
From complete application submission to FINMA decision. Pre-application discussion (Vorbesprechung) with FINMA recommended before formal submission.
Who the FinTech licence is for
The BankG Art. 1b licence was designed for innovation-stage companies that need to accept public deposits but do not need to invest or lend those deposits. It is the middle tier between SRO membership (up to CHF 1M) and a full banking licence (unlimited deposits with investment).
- Payment platform accepting client funds (fiat or crypto) below CHF 100M
- Crypto custody without investment or lending (stablecoin issuer without yield)
- Digital wallet infrastructure holding client balances in CHF or foreign currency
- Cross-border payment aggregation and settlement services
- Buy-now-pay-later (BNPL) platforms accepting advance deposits from merchants
- Tokenised deposit platforms (non-interest-bearing, non-invested)
- Payroll and treasury management platforms holding employer float balances
Minimum capital — what it covers
The minimum capital is the higher of 3% of the public deposits held and CHF 300,000 (BankV Art. 17a): CHF 300,000 is only the floor for a small deposit book, while a firm approaching the CHF 100M deposit cap must hold up to ~CHF 3,000,000. It must be fully paid-in and deposited with a Swiss bank before FINMA application, and it is not consumed by operating costs. If losses reduce capital below the required minimum (the higher of 3% of deposits and CHF 300,000), FINMA must be notified immediately and capital must be restored. Budget separately for application advisory costs (typically CHF 30,000–100,000 for a complete submission) and ongoing compliance infrastructure.
| Criterion | FinTech Licence | Full Banking Licence | SRO Membership |
|---|---|---|---|
| Minimum capital | CHF 300K or 3% of deposits | CHF 10,000,000+ | CHF 100,000 (AG) |
| Max public deposits | CHF 100,000,000 | Unlimited | CHF 1,000,000 (sandbox) |
| Interest on deposits | Not permitted | Permitted | Not permitted (sandbox) |
| Investment of deposits | Not permitted | Permitted | Not permitted |
| Application timeline | 6–12 months | 12–24 months | 2–4 months |
| FINMA supervision | Direct | Direct (intensive) | Indirect (via SRO) |
| Legal basis | BankG Art. 1b | BankG Art. 1a | AMLA Art. 24 |
Key Data
FINMA FinTech Licence — Key Parameters
Banking Act (BankG) Art. 1b — the FinTech licence
CHF 100M
Maximum deposits accepted
FinTech licence allows accepting public deposits up to CHF 100M (no investment in credit).
CHF 300K
Minimum capital (floor)
Floor of CHF 300,000, or 3% of public deposits if higher (BankV Art. 17a) — still far below a full banking licence (CHF 10M+).
6–12 mo
Application processing time
Streamlined vs. full bank licence. Pre-consultation with FINMA strongly recommended.
No interest
Deposit restriction
FinTech licensees may not pay interest on accepted deposits.
Application Package
What FINMA requires
in a complete Art. 1b application
FINMA does not publish a standardised application checklist for the FinTech licence. The following represents what a complete application package must contain based on FINMA practice and the requirements set out in BankG Art. 1b and the Banking Ordinance.
Business plan
3-year financial projections, revenue model, target client base, geographic scope, and transaction volume estimates.
Governance documentation
Organisation chart, board composition, management CVs, fit-and-proper declarations for all directors and key functions.
AML programme
Written AML/KYC policy, risk appetite statement, compliance officer appointment, suspicious activity reporting procedures.
IT and operational security concept
FINMA expects a documented IT risk framework, data security policy, business continuity plan, and cyber incident response procedures.
Capital proof
Bank confirmation that the required minimum capital — the higher of 3% of public deposits or CHF 300,000 (BankV Art. 17a) — is deposited and available. The bank must be a Swiss bank — not a foreign institution.
Shareholder structure
Full transparency on ultimate beneficial ownership (OR Art. 697j). Corporate shareholders require full UBO chain to the natural-person level.
Legal opinions
For novel business models: legal opinion from Swiss counsel confirming the activity falls within the FinTech licence scope and does not trigger additional FINMA licence requirements.
Vorbesprechung first
Pre-application discussion with FINMA
Before submitting a formal FinTech licence application, Goldblum & Partner facilitates a Vorbesprechung — a pre-application discussion with FINMA — to validate the business model, identify documentation gaps, and receive informal guidance on the regulatory interpretation of novel activities. This step cannot be skipped for applications involving stablecoins, tokenised deposits, or multi-currency float accounts. A rejected application does not preclude resubmission, but it delays the project by 6–12 additional months and incurs significant advisory costs.
FAQ
Frequently asked
questions
Precise answers to the most common questions about forming a company in Switzerland. For specific advice on your structure, book a free consultation.
Free consultationOfficial Sources
- FINMA — Swiss Financial Market Supervisory Authority
Grants and directly supervises the FinTech licence; every capital, timeline and AML claim on the page traces to FINMA practice.
- Banking Act (SR 952.0)
Art. 1b is the licence's legal basis and Art. 1a the full banking licence contrast; the page repeatedly cites both.
- Anti-Money Laundering Act (SR 955.0)
Basis for the full-AMLA-compliance and MROS-reporting obligations the page asserts for licence holders.
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