FINMA License Switzerland: Licensing Guide (2026)

The Swiss Financial Market Supervisory Authority (FINMA) is Switzerland’s integrated financial regulator, responsible for licensing and supervising banks, securities dealers, asset managers, collective investment schemes, insurance companies, and other financial intermediaries. A FINMA license Switzerland is a prerequisite for conducting regulated financial services in Switzerland. This guide explains the main FINMA licence categories, requirements, and the application process for 2026.

Official FINMA guidance, application forms, and fee schedules are published at finma.ch.

FINMA Licence Categories

Licence Type	Legal Basis	Regulates
Banking licence	Banking Act (BankG)	Banks and savings institutions
Securities firm / dealer	FinIA	Securities dealers, investment firms
Asset manager (individual portfolios)	FinIA	External/independent asset managers
Fund management company	CISA/KAG	Managers of collective investment schemes
FINMA-authorised representative	CISA	Swiss representatives of foreign funds
Insurance company	ISA/VAG	Direct insurers and reinsurers
Insurance intermediary	ISA	Brokers, agents
FinTech licence	BankG (Art. 1b)	Limited banking activities
Self-regulatory organisation (SRO)	AMLA	AML supervisory bodies

Banking Licence (BankG)

A full banking licence is required for any entity that:

Accepts deposits from the public exceeding CHF 100,000 in aggregate
Publicly solicits deposits

Key requirements:

Minimum capital: CHF 10 million (in practice, significantly more required based on business model and risk)
Minimum 2 directors in Switzerland or accessible to FINMA
Fit and proper requirements for directors and significant shareholders (20%+ holders)
Adequate risk management, compliance, and internal audit systems
FINMA-approved auditor (Prüfgesellschaft)
Swiss domicile

Process: Application to FINMA with a detailed business plan, capital proof, governance documentation, and personal questionnaires for all key persons. FINMA typically takes 12–24 months for a full banking licence.

Cost: FINMA fees are CHF 10,000–100,000+ depending on complexity. Legal and advisory costs for a banking licence application: CHF 500,000–2,000,000.

For the company vehicle underlying a banking or financial institution, see our AG formation Switzerland guide — Swiss banks and securities firms are typically incorporated as AGs.

Securities Firm Licence (FinIA)

Under the Financial Institutions Act (FinIA, in force 2020), securities firms are:

Securities dealers operating on their own account
Investment firms managing third-party assets on a discretionary basis (portfolio managers of individual accounts with CHF 100,000,000+ AUM, or 20+ clients)

Requirements:

Minimum capital: CHF 1.5–10 million depending on activity
Senior management based in Switzerland
Fit and proper assessment
Membership in a FINMA-recognised ombudsman scheme (FinSA)

Asset Manager Licence (FinIA)

Independent asset managers (IAMs) managing individual client portfolios must be licensed under FinIA.

Key requirements:

Minimum capital: CHF 100,000 (or 25% of annual costs, whichever is higher; max CHF 10 million)
At least one full-time qualified manager with relevant experience
Affiliated with a FINMA-supervised prudential supervisory organisation (SO / Aufsichtsorganisation)
Registered with a FINMA-recognised ombudsman (FinSA)
Compliance function and risk management proportionate to size

Threshold: Required if managing third-party assets on a discretionary basis. Below CHF 100,000,000 AUM with fewer than 20 clients: lighter requirements under SO supervision rather than direct FINMA authorisation.

Timeline: 6–18 months for asset manager licensing. FINMA-supervised SOs (e.g., ARIF, ASG, OAR-G) handle the initial assessment.

Fund Management Company Licence (CISA)

Fund management companies that manage Swiss collective investment schemes (funds) require FINMA authorisation under the Collective Investment Schemes Act (CISA).

Key requirements:

Minimum capital: CHF 1 million (or higher based on AUM)
At least 2 qualified senior managers in Switzerland
Adequate infrastructure, risk management, and compliance
Depositary bank (Swiss-licensed bank) for the fund assets

For Swiss limited partnerships for collective investment schemes (KGK / PE/VC funds): the general partner must also be FINMA-licensed if it is a fund management company.

FinTech Licence (Art. 1b BankG)

The FinTech licence is a lighter-touch banking authorisation for non-bank financial innovators.

Eligibility: Companies that:

Accept public deposits or cryptocurrency assets
Do not exceed CHF 100,000,000 in deposits
Do not invest or pay interest on the accepted funds

Requirements:

Minimum capital: CHF 300,000
Maximum deposits: CHF 100,000,000
Simplified governance compared to full banking licence
Swiss domicile

The FinTech licence is used by crypto asset custodians, payment institutions, and financial innovators who need to hold client funds but do not conduct full banking operations. For the corporate structure underlying a FinTech licence application, a Swiss GmbH or AG is standard — see our GmbH formation Switzerland and AG formation Switzerland guides.

Crypto / Blockchain: FINMA Classification

FINMA does not have a specific “crypto licence” — instead, crypto activities are classified under existing categories:

Activity	FINMA Licence Required
Crypto exchange (>CHF 100M deposits)	Banking licence
Crypto exchange (asset custody)	FinTech licence or banking licence
Crypto asset management	FinIA asset manager licence
Crypto token issuance (utility)	Typically no FINMA licence (AMLA SRO required)
Crypto token issuance (security token)	Securities dealer licence may apply
Crypto bank (SEBA/AMINA model)	Full banking licence

FINMA’s 2018 ICO guidance and subsequent DLT Act amendments clarified the regulatory framework. The full statutory basis is available at fedlex.admin.ch. For detailed guidance on crypto structuring, see our crypto license Switzerland guide.

Anti-Money Laundering (AML) — Non-FINMA Path

Financial intermediaries not falling under FINMA-supervised entities must affiliate with an AMLA-approved Self-Regulatory Organisation (SRO). This includes:

Independent insurance agents
Financial advisers without discretionary management
Certain crypto service providers
Payment service providers below the FinTech licence threshold

SRO membership is not a FINMA licence — it is fulfilment of the AML compliance obligation under the Anti-Money Laundering Act (AMLA).

Application Process

Pre-consultation: Request a preliminary meeting with FINMA (strongly recommended before the full application)
Prepare application package: Business plan, financial projections, governance documents, personal questionnaires for key persons, AML/compliance framework
Submit to FINMA: Through FINMA’s online portal (EHP)
FINMA review: FINMA may request clarifications; formal questions and answers
FINMA decision: Approval (with or without conditions) or rejection
Ongoing supervision: Annual reporting, FINMA-approved audit, ongoing fit and proper monitoring

For the holding or operational entity that will hold the licence, see our holding company Switzerland and company formation Switzerland guides.

Frequently Asked Questions

How long does FINMA licensing take?

FinTech licence: 6–12 months. Asset manager licence: 6–18 months via SO. Full banking licence: 12–24 months. FINMA processing times depend on application quality and complexity.

Can a foreign bank passport into Switzerland?

No EU-style financial passport exists for Switzerland. EEA financial institutions cannot rely on their home-country licence to conduct Swiss business — a Swiss FINMA licence is required, or business is conducted cross-border without Swiss establishment (which is restricted for certain activities).

What are FINMA’s ongoing supervisory fees?

FINMA charges annual supervisory fees based on the institution’s size and risk category. For a small asset manager: CHF 5,000–20,000 per year. For banks: CHF 50,000–500,000+ depending on balance sheet.

What is the minimum capital requirement for a Swiss banking licence?

The statutory minimum is CHF 10 million, but in practice FINMA requires significantly more based on business model and risk profile. Legal and advisory costs for the application alone typically reach CHF 500,000–2,000,000.

Do crypto companies need a FINMA licence in Switzerland?

It depends on the activity. Crypto exchanges accepting over CHF 100 million in deposits require a banking licence. Custody-focused exchanges may use a FinTech licence. Crypto asset managers need a FinIA licence. Utility token issuers typically require SRO membership rather than a FINMA licence.

What is the FinTech licence in Switzerland?

The FinTech licence (Art. 1b BankG) is a lighter-touch banking authorisation for entities that accept public deposits up to CHF 100 million but do not invest or pay interest on those funds. Minimum capital is CHF 300,000. It is used by crypto custodians, payment institutions, and financial innovators.

What is an SRO and when is it required?

A Self-Regulatory Organisation (SRO) is an AMLA-approved body that provides AML supervision for financial intermediaries not subject to direct FINMA oversight. It is required for financial advisers without discretionary management, certain crypto service providers, and payment service providers below the FinTech threshold.

What is the asset manager licence threshold under FinIA?

Independent asset managers managing individual client portfolios on a discretionary basis require a FinIA licence. Below CHF 100 million AUM with fewer than 20 clients, lighter requirements apply under SO (Aufsichtsorganisation) supervision rather than direct FINMA authorisation.

What does FINMA’s pre-consultation process involve?

A pre-consultation is an informal preliminary meeting with FINMA recommended before submitting a formal application. It allows applicants to clarify which licence category applies, identify documentation requirements, and assess whether the proposed structure is approvable — avoiding costly errors in the formal submission.

Can I use a Swiss GmbH to hold a FINMA licence?

Most FINMA-regulated entities use an AG (Aktiengesellschaft) structure due to its stronger capital and governance framework. A GmbH is permissible for certain smaller operations, but FINMA will assess whether the structure is appropriate for the regulated activity. Seek advice on entity selection before incorporating.

Get Expert Advice on Your FINMA Licence Application

FINMA licence applications are among the most document-intensive and technically demanding regulatory processes in Switzerland. Pre-application structuring — entity form, capital planning, governance framework, and AML compliance design — determines whether an application succeeds and how long it takes.

Morgan Hartley and the Lawsupport team have advised clients on FINMA licensing, VASP registration, SRO membership, and crypto/blockchain legal structuring since Crypto Valley’s earliest years.

Request a Free Assessment — contact us to discuss your FINMA licensing requirements:

Phone: +41 44 51 52 592
Email: info@lawsupport.ch
Address: Grafenauweg 4, 6300 Zug, Switzerland

Request a Free Assessment →

Lawsupport (Morgan Hartley Consulting GmbH) | Grafenauweg 4, Zug | +41 44 51 52 592 | info@lawsupport.ch