FINMA Licensing
Swiss FINMA licence — six pathways.
From sandbox to full banking.
Switzerland's financial regulatory framework spans six distinct pathways — from the sandbox exemption (CHF 1M deposit limit, no licence required) to the full banking licence (CHF 10M+ capital, FINMA direct supervision). Selecting the correct pathway before incorporation is critical. Our Zug-based team advises on regulatory scoping, application preparation, and ongoing compliance.
CHF 300K
FinTech licence capital
6–18 mo
FINMA review timeline
2–4 mo
SRO membership path
CHF 1M
Sandbox deposit limit
Licence Types
Six FINMA regulatory pathways
from sandbox to full banking licence
Switzerland's financial regulatory framework spans six distinct pathways depending on the activity, deposit volume, and client base. Choosing the correct pathway before incorporation avoids costly restructuring after the fact — FINMA does not permit retroactive licence upgrades without a new application.
Full banking licence
BankG Art. 1aAuthorises deposit-taking, lending, and payment services without restriction. Highest capital requirement and most intensive FINMA oversight. Required for commercial banks, cantonal banks, and securities dealers conducting deposit-taking activities.
Typical use: Banks, securities dealers, universal financial institutions
FinTech licence
BankG Art. 1bLighter-touch licence for innovation-stage entities accepting public deposits up to CHF 100,000,000. No interest payment and no investment of deposits permitted. Introduced 2019 as part of Switzerland's fintech promotion framework.
Typical use: Fintech startups, payment platforms, deposit innovators
Detailed guide →DLT trading facility
FinfraG Art. 73a–73fEnables operation of a trading venue for DLT-based securities and crypto assets. Established by the DLT Act (in force 1 August 2021). Allows admission of retail participants — unlike traditional exchanges. Novel licence type with limited precedent.
Typical use: Crypto exchanges, DLT securities venues
Detailed guide →Portfolio manager / trustee
FinIA Art. 17–24Required for independent asset managers and trustees managing client portfolios on a discretionary basis. Must affiliate with a FINMA-supervised supervisory organisation (SO). Thresholds: ≥20 clients OR ≥CHF 5M AUM OR ≥CHF 50,000 annual income from management.
Typical use: Independent asset managers, family offices, trustees
SRO membership pathway
AMLA Art. 24; GwGFor lower-risk financial intermediaries and VASPs that are not required to hold a FINMA licence but must satisfy AML obligations. SROs (VQF, PolyReg, ARIF) are FINMA-supervised self-regulatory organisations. Faster and lower-cost than a full licence — the most common first step for crypto businesses.
Typical use: VASPs, crypto exchanges below full licence threshold
Detailed guide →Sandbox exemption
BankV Art. 6Entities accepting public deposits up to CHF 1,000,000 are exempt from FINMA licensing requirements, provided funds are not invested, no interest is paid, and depositors are informed in writing that the entity is not supervised by FINMA and deposits are not covered by deposit protection. Not a licence — a statutory threshold exemption.
Typical use: Early-stage pilots, proof-of-concept platforms
Cross-cutting requirements — all FINMA licence types
GmbH technically eligible but AG preferred by FINMA for regulated entities. Shareholder privacy and share structure flexibility are advantages.
At least two managing directors with relevant professional qualifications and fit-and-proper status. FINMA conducts background checks.
At least one director with signing authority must be domiciled in Switzerland (OR Art. 718a). Nominee director service available through Goldblum & Partner.
FINMA requires a genuine Swiss business presence, not merely a letter-box address. Virtual office or serviced office acceptable if real operational activity is present.
Mandatory for all FINMA-licensed entities and SRO members. Must be independent from revenue-generating functions. External compliance officer arrangements available.
A pre-application discussion with FINMA (Vorbesprechung) before formal submission significantly reduces rejection risk. Goldblum & Partner facilitates these discussions.
Key Data
FINMA Licensing — Overview
Switzerland's financial market supervisory framework
8+
FINMA license categories
Banks, securities firms, fund managers, asset managers, insurance, FinTech, and more.
6–24 mo
Typical processing time
Depends on license type, complexity, and completeness of application documentation.
900+
Regulated entities (FINMA)
Total FINMA-supervised institutions including banks, funds, and insurers.
AG preferred
Entity type
FINMA-regulated entities typically require an AG (Aktiengesellschaft) structure.
Application Process
Six steps to a FINMA licence
from scoping to supervision
01
Determine the correct licence
Activity analysis: deposit volume, client type, investment / interest intent. Incorrect pathway selection is the most common — and costly — error. Goldblum & Partner conducts a regulatory scoping assessment before any incorporation.
02
Incorporate the Swiss AG
FINMA requires a Swiss-incorporated entity before the formal application. Formation takes 3–6 weeks (or 1–3 days via shelf AG). Articles of association must reflect the intended regulated activity.
03
Pre-application discussion with FINMA
A Vorbesprechung (pre-application discussion) with FINMA before formal submission significantly reduces rejection risk. FINMA signals whether the proposed business model is regulatorily viable and which documentation gaps exist.
04
Build the compliance framework
AML programme, compliance officer appointment, internal controls, governance policies, and IT/risk systems. FINMA reviews the adequacy of the compliance framework as part of the application — not after licence grant.
05
Submit formal application
Full application package: business plan, financial projections (3-year), shareholder structure, management CVs, AML programme documentation, IT security concept, and proof of capital. FINMA review: 6–18 months depending on licence type and complexity.
06
Post-licence ongoing obligations
Annual accounts and regulatory reports to FINMA. Ongoing AML monitoring and suspicious activity reporting. FINMA supervision fees. Any material change to business model requires prior FINMA notification or approval.
Zug — Switzerland's regulated fintech and crypto hub
Zug's Crypto Valley hosts more blockchain and fintech companies per capita than any other Swiss canton. The 11.85% combined corporate tax rate, the Zug Handelsregister's processing efficiency, and the proximity of FINMA-experienced legal and compliance service providers make Zug the default incorporation canton for FINMA-licence applicants. Goldblum & Partner's office at Baarerstrasse 25, Zug positions clients within this ecosystem from day one.
Crypto & DLT services
Build a regulated crypto business in Switzerland
FINMA crypto licence
VASP, SRO membership and full FINMA licence pathways for crypto-asset service providers.
Swiss DLT licence
Trading-venue authorisation under FinfraG Art. 73a — for DLT-securities exchanges.
Crypto company formation
Crypto Valley Zug structures, banking, custody and FINMA-ready governance.
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 — Official Website
Swiss Financial Market Supervisory Authority
- BankG — Swiss Banking Act
Federal Banking Act — banking licence (Art. 1a) and FinTech licence (Art. 1b)
- FinfraG — Financial Market Infrastructure Act
DLT trading facility licensing under Art. 73a–73i
- GwG — AML Act
Swiss AML Act — applies to all FINMA-regulated entities
- FINMA — Authorised Institutions Register
Search all FINMA-licensed banks, asset managers, and insurers
Free Consultation
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in Switzerland?
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Baarerstrasse 25 · 6300 Zug · Switzerland · Est. 2007