Digital Payments & Fintech - Switzerland

Since 1 January 2019, FINMA may grant a FinTech licence to entities that accept public deposits of up to CHF 100 million (or crypto-assets), provided the funds are not invested and no interest is paid. Capital and governance requirements are lighter than a full banking licence. Entities below CHF 1 million fall under the sandbox and need no licence at all.

In force since August 2017 and amended April 2019, the sandbox allows acceptance of public deposits up to CHF 1 million without any banking or FinTech licence, subject to AML compliance and affiliation to a self-regulatory organisation. It is intended purely as an innovation testing space.

On 22 October 2025 the Federal Council opened a consultation (deadline 6 February 2026) to amend the Financial Institutions Act. The proposal creates two new licence categories — a payment institution licence and a crypto institution licence — designed to replace the existing FinTech licence, which authorities consider insufficiently tailored to payment-service and digital-asset business models. Entry into force is expected late 2026 or early 2027.

Switzerland's open-banking model is entirely voluntary and industry-driven; there is no legal obligation for banks to share customer data with third-party providers. The SIX bLink platform (live since 2020) provides standardised APIs. On 25 November 2025, multibanking for retail clients launched with 30 banks supplying data and eight banks plus two fintechs aggregating it. In December 2025 the Federal Council confirmed no regulatory mandate for open-data interfaces is planned for the near term.

SIX and the Swiss National Bank launched the SIC5 infrastructure (new-generation Swiss Interbank Clearing) with an instant-payment service in November 2023. Since 20 August 2024, over 100 financial institutions covering approximately 95% of Swiss retail payment volumes must accept incoming instant payments; all remaining SIC participants must comply by November 2026 at the latest. The SNB decision to make acceptance mandatory dates to June 2021.

Buy-now-pay-later products in Switzerland are governed by the existing Consumer Credit Act (KKG), which covers loans between CHF 500 and CHF 80,000; loans repayable within three months are statutorily exempt. Switzerland is not an EU member and is not bound by the EU Consumer Credit Directive II (CCD II). No Switzerland-specific BNPL reform has been proposed as of mid-2026.