Crypto license in Switzerland: FINMA requirements (2026)

The Swiss Federal Council launched a public consultation on amending the Financial Institutions Act (FinIA) to abolish the fintech licence and replace it with two new categories: Payment Institutions (exclusive right to issue regulated stablecoins, no CHF 100 m deposit cap) and Crypto Institutions (lighter-touch licence for crypto custody, trading, and related services). The consultation closed 6 February 2026; implementation is expected in late 2026 or 2027.

FINMA published guidance requiring banks and securities firms to clearly disclose crypto-based asset holdings in their annual financial statements, tightening supervisory transparency expectations for supervised institutions with digital-asset exposure on their balance sheets.

FINMA licensed BX Digital AG (part of Boerse Stuttgart Group) as the world's first DLT trading facility under the Financial Market Infrastructure Act, enabling on-chain trading and delivery-versus-payment settlement of DLT securities on Ethereum via smart contract. The licence became legally effective 14 May 2025, realising the licence category created by the 2021 DLT Act.

FINMA issued Guidance 06/2024 on stablecoins, setting minimum requirements for bank default guarantees used by stablecoin issuers to avoid needing a banking licence, and flagging heightened money-laundering, sanctions-evasion, and reputational risks for guaranteeing banks. The guidance also highlighted rising illicit use of stablecoins for sanctions circumvention.

The Federal Act on the Adaptation of Federal Law to Developments in Distributed Electronic Register Technology (DLT Act) came fully into force, establishing a new DLT trading facility licence under FinMIA, creating legal rules for the segregation of crypto assets in insolvency, and providing the basis for trading rights via blockchain registers. This completed a two-phase entry into force (Phase 1: civil law amendments on 1 February 2021).

The first tranche of the DLT Act entered into force, amending the Code of Obligations and other civil laws to create 'ledger-based securities', a new legal instrument enabling rights to be tokenised and transferred on a blockchain with the same legal certainty as traditional certificated securities. This gave Switzerland the world's first bespoke civil-law foundation for DLT securities.

Following FINMA's August 2019 blockchain-payment guidance, Switzerland became one of the first jurisdictions globally to enforce the FATF Travel Rule for virtual asset service providers, mandating transmission of originator and beneficiary data for transfers above CHF 1,000, below the FATF default of USD 1,000, and prohibiting transfers to unhosted wallets of unregulated providers.

FINMA granted banking and securities dealer licences to SEBA Crypto AG (Zug) and Sygnum (Zurich), making them the world's first regulated crypto-native banks. The twin approvals demonstrated that Switzerland's financial regulatory framework could accommodate full-service institutions bridging digital and traditional assets, cementing 'Crypto Valley' as a global hub.

The Federal Council adopted its comprehensive report 'Legal Framework for Distributed Ledger Technology and Blockchain in Switzerland', concluding the legal framework was largely adequate but identifying selective gaps, particularly around DLT-based securities, a new trading facility licence, and bankruptcy rules for crypto, directly triggering the drafting of what became the 2021 DLT Act.

FINMA issued its ICO guidelines establishing a three-category taxonomy, payment tokens (subject to AML law, not securities), utility tokens (not securities if functional at issuance), and asset tokens (treated as securities under FMIA), giving ICO organisers regulatory clarity and creating the classification framework that still underpins Swiss crypto regulation today.

The city of Zug launched a pilot allowing residents to pay for administrative services in Bitcoin (capped at CHF 200), partnering with Bitcoin Suisse AG to absorb exchange-rate risk. The initiative established Zug's 'Crypto Valley' identity and attracted a wave of blockchain companies to Switzerland, shaping the ecosystem that regulators would later formalise.

The Federal Council published Switzerland's first official analysis of virtual currencies, concluding that professional trading in cryptocurrencies and the operation of trading platforms generally fall within the scope of the Anti-Money Laundering Act (AMLA), imposing KYC and due-diligence obligations, the foundational legal characterisation that underpins all subsequent Swiss crypto regulation.