Fintech & digital payments rules in Switzerland (2026)

FINMA published Guidance 01/2026 setting out supervisory expectations for institutions holding crypto-based assets on behalf of clients, addressing segregation, safekeeping obligations, and operational risks. Signals that crypto custody is now treated as a mainstream supervisory concern on par with traditional asset safekeeping.

The Federal Council opened a consultation on FinIA amendments proposing to abolish the 2019 FinTech banking licence and introduce two FINMA-supervised licence categories: Payment Instrument Institutions (stablecoin issuers / payment firms, no CHF 100 m cap) and Crypto Institutions (lighter-touch than securities firms). Consultation closed 6 February 2026; implementation expected late 2026 – early 2027.

The Swiss Parliament enacted the Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners (LETA) together with a revised AMLA, creating a centralised federal register of beneficial owners. A key FATF compliance step that imposes enhanced due-diligence obligations on fintech and crypto intermediaries processing company transactions.

SIX and the Swiss National Bank formally launched the instant-payment service commercially; all banks that processed more than 500,000 incoming SIC transactions in 2020 became obligated to accept incoming instant payments 24/7. Unlike EU peers, Switzerland opted for regulatory compulsion from day one rather than voluntary adoption; remaining institutions must comply by end-2026.

FINMA Guidance 06/2024 clarified that stablecoin holder-redemption claims normally qualify as public deposits under the Banking Act, requiring a banking licence or FinTech licence for issuers. FINMA also warned supervised institutions of heightened money-laundering, terrorist-financing, and sanctions-circumvention risks from anonymous stablecoin transfers.

SIX and the Swiss National Bank launched the fifth generation of the Swiss Interbank Clearing (SIC5) system, replacing legacy infrastructure and enabling round-the-clock real-time gross settlement. SIC5 was the prerequisite for the August 2024 mandatory instant-payment rollout and represents the most significant overhaul of Swiss payment infrastructure in decades.

The revised AMLA and updated FINMA Anti-Money Laundering Ordinance (AMLO-FINMA) took effect, implementing priority FATF recommendations from Switzerland's 2016 mutual evaluation: tightened beneficial-ownership verification, mandatory client-data updates, expanded suspicious-activity reporting, and extended crypto-asset coverage including DLT trading facilities.

The Federal Act on the Adaptation of Legislation to DLT came fully into force, introducing ledger-based securities (Registerwertrecht) in the Code of Obligations, a new DLT Trading Facility licence category under FMIA, and bankruptcy-law protection for segregated crypto assets. Switzerland became one of the first countries with a comprehensive statutory framework for tokenised financial instruments.

FinSA (SR 950.1) and FinIA (SR 954.1) together with their implementing ordinances took effect, creating a cross-sectoral conduct-of-business rulebook for all financial service providers and a unified licensing hierarchy for financial institutions — including fintech and asset-management firms — broadly paralleling MiFID II and PRIIPS but with Swiss-specific adaptations.

The Banking Act amendment creating a 'light' FinTech licence category took effect, allowing non-bank entities to accept public deposits up to CHF 100 million without a full banking licence, provided deposits are not reinvested and bear no interest. This was Switzerland's first dedicated prudential licence for payment and fintech firms and FINMA adapted its circulars accordingly by 1 July 2019.

FINMA released guidelines on Initial Coin Offerings establishing the foundational token taxonomy still in use today: payment tokens (subject to AML law), utility tokens (may avoid financial-market regulation if fully functional at issuance), and asset tokens (treated as securities requiring prospectus and conduct obligations). Hybrid tokens attract combined requirements.

A Federal Council amendment to the Banking Ordinance (adopted 5 July 2017, in force 1 August 2017) created Switzerland's first fintech regulatory sandbox — allowing firms to accept public deposits from more than 20 customers up to CHF 1 million without a banking licence — and extended the settlement holding period for third-party funds from 7 to 60 days, reducing barriers to entry for payment and crowdfunding platforms.