Global consultancy EY has released a new licensing guide for market participants in Switzerland, offering practical guidance for industry players including fintech firms, distributed ledger technology (DLT) trading platforms, and payment system operators.

It provides an overview of the main types of FINMA licenses and authorizations, outlines key regulatory frameworks, and explains specific requirements.

The guide identifies five principal legal acts governing Switzerland’s financial sector under the supervision of the Swiss Financial Market Supervisory Authority (FINMA): the Banking Act (BA), the Insurance Supervision Act (ISA), the Financial Market Infrastructure Act (FinMIA), the Financial Institutions Act (FinIA), and the Collective Investment Schemes Act (CISA).

It also highlights the Anti-Money Laundering Act (AMLA) and the Financial Services Act (FinSA), which affect the financial services sector but which fall outside of FINMA’s direct supervisory scope.

The Fintech License

For fintech companies, BA is the core regulation. Under this law, the Fintech License allows companies to accept public deposits without engaging in traditional banking activities such as lending or paying interest. Introduced in January 2019, it offers a lower regulatory burden than a full banking license, while still requiring compliance with anti–money laundering rules and robust risk management.

The license allows holders to accept up to CHF 100 million in public deposits or crypto-assets, without investing or paying interest on them. By contrast, a traditional banking license targets institutions accepting deposits above CHF 100 million, investing or paying interest on those deposits, and providing financing on their own account while refinancing extensively with other banks.

Eligible applicants include limited companies, partnerships with unlimited partners, and limited liability companies, and minimum capital must equal at least 3% of public deposits and crypto-assets held in collective deposit, with a floor of CHF 300,000, fully paid up and maintained at all times.

Governance requirements include management located in Switzerland, at least a third of the governing body independent of management, and assurance of irreproachable business conduct by key participants and management.

Licensees must also implement effective risk management systems covering market, credit, default, settlement, liquidity, image, operational and legal risks. They must maintain clear separation of internal functions, in particular lending, trading, asset management and settlement, and have an independent internal audit function. They must also appoint a recognized regulatory audit firm for ongoing supervision.

Just like the banking license, the Fintech License also comes with costs, which are covered by fees and supervisory levies. To manage these, FINMA has created a new section in its Fees and Levies Ordinance especially for Fintech License holders.

The supervisory levy includes a fixed basic levy of CHF 3,000 plus an additional levy calculated as 20% based on the company’s balance sheet total, and 80% based on the company’s gross income.

On top of these levies, companies must also pay for relevant financial and regulatory audits, payable to the respective audit companies. FINMA estimates this amount to be around CHF 40,000 to CHF 50,000, which is significantly less than what is due for a regular banking license.

DLT Trading Facilities

In addition to BA, FinMIA is another key regulation for fintech companies, in particular those operating digital asset trading platforms and payment systems.

Financial market infrastructure groups, including DLT trading platforms, must apply for licensing as a DLT Trading Facility. A DLT Trading Facility is a financial market infrastructure which enables multilateral trading of DLT securities on a professional basis. These book-entry securities are transferred and held on a blockchain-based platform.

DLT Trading Facilities are required to at least admit legal entities other than supervised financial institutions or private clients as participants; provide central custody of DLT securities under uniform rules and procedures; or offer clearing and settlement for DLT securities.

Licensing of these facilities is based on the DLT Act, which entered into force in Switzerland in August 2021 and created a new type of financial market infrastructure.

As part of the licensing process, FINMA requires applicants to address business continuity, including settlement infrastructure on public blockchains. To limit operational risks, licensees are required to carry out technical checks of the technology used, such as checking the source code used by smart contracts. Robust risk management and control systems are also mandatory.

Minimum capital requirements include CHF 1 million for DLT Trading Facilities without central custody or clearing and settlement services; or CHF 5 million for DLT trading facilities providing these services. Small DLT Trading Facilities must hold at least CHF 500,000 or 5% of all DLT securities in custody.

Payment Systems

For companies operating payment systems, FINMA authorization is only required if necessary for the proper functioning of the financial market or the protection of financial market participants, and if the payment system is not operated by a bank.

Applicants must have at least at CHF 1.5 million in minimum capital and provide collateral. Governance requirements mirror those of Fintech Licensees, and include proven integrity of qualified participants and management; clear separation between management, oversight, and internal audit functions; a supervisory body with at least three members; effective risk management and internal control systems, plus an independent internal audit function; and a recognized regulatory audit firm must also be appointed for ongoing supervision.

Current License Holders

To date, FINMA has licensed one DLT Trading Facility, namely BX Digital, which uses the Ethereum blockchain to trade and settle DLT securities, and five fintech companies.

Yapeal is a Swiss app-based bank which combines a private account with a Visa Debit card. It also offers embedded finance through a B2B2X model, claiming over 850 corporate clients, and partnering with 25 Swiss businesses to integrate its financial services.

Bivial, formerly known as Klarpay, provides multi-currency accounts, payment services, and acceptance, serving both individuals and businesses. Since commencing operations, Bivial has remained consistently profitable, doubling its annual profit in 2024 compared to the previous year. It now serves nearly 500 corporate clients.

Fiat24, operated by SR Saphirstein, is a global payment app leveraging blockchain technology to give clients access to a Swiss IBAN account in their name, a Visa debit card, foreign exchange (FX), and more; and Relio is a digital Swiss bank account for small and medium-sized enterprises (SMEs).

Finally, Swiss4, once a digital banking startup with approximately 250 customers, is currently in liquidation. FINMA opened bankruptcy proceedings against the fintech institution on March 4, 2025, citing over-indebtedness and severe liquidity issues.

Featured image: Edited by Fintech News Switzerland, based on images by jofreepik and creativeart via Freepik