01
The perimeter follows the actual service
Receiving client money, holding assets, discretionary management, payments, exchange, lending, issuing instruments, securities trading and advertising are analysed separately. Calling a business an IT platform or consultancy does not remove regulation where contracts and cash flows show financial activity.
02
Banks and securities firms sit inside full prudential supervision
Professional acceptance of public deposits and specified securities activities require the relevant FINMA licence. Capital, owners, governance, organisation, risk, audit, IT, outsourcing, recovery and the fitness of responsible persons are assessed.
A Swiss financial project starts with its regulatory perimeter: the legal character of money flows and powers determines whether a banking, fintech, portfolio-manager, trustee or other authorisation is required.
03
The FinTech licence has narrow boundaries
The Article 1b Banking Act licence permits public deposits or crypto-based assets up to CHF 100 million where they are neither invested nor interest-bearing. Clients must be told that these assets lack depositor privilege and protection; a model outside the conditions needs a different analysis.
04
Portfolio managers and trustees are licensed before operating
Commercial management of another person's financial assets or a separate trust fund requires FINMA authorisation. The applicant proves a Swiss domicile, qualified management, suitable organisation, financial guarantees and affiliation with a supervisory organisation for ongoing supervision.
05
AMLA may apply without a prudential licence
Payments, exchange, fiduciary, wallet and other financial-intermediation functions may fall under the Anti-Money Laundering Act and SRO supervision. KYC, beneficial ownership, risk classification, sanctions, transaction monitoring, reporting and records are built before launch.
06
The application must describe an operational business
FINMA tests alignment between agreements, financial model, capital, governance, people, systems, client-asset controls and exit plan — not a presentation alone. Material post-authorisation changes may need advance approval.
FAQ
Frequently asked questions
Can the service launch before licensing?
Where the activity is regulated, authorisation is required before commercial operations start.
Is a FinTech licence a banking licence?
No. It is a distinct, limited regime that does not permit investing accepted assets or paying interest on them.
Does a Swiss trustee need a licence?
A commercial trustee falls within FinIA and must obtain FINMA authorisation where the statutory criteria are met.
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