Crypto License in Switzerland

Licensing Support at a Glance

Item	Gofaizen & Sherle offering
Main route	Membership in a FINMA-recognized SRO
Existing company	Basic package for application preparation
New operation	Fully Operational package with company and local team setup
Local arrangements	Assistance finding a board member, AML officer and office
Banking	Provider assessment and account-application support
Scope boundary	Activities requiring separate authorization need individual assessment
Market access	SRO membership does not provide a MiCA passport

Is Switzerland the Right Fit for Your Financial Business?

• May fit: exchanges, brokers, OTC desks and payment businesses prepared for local governance and ongoing compliance.
• May not fit: projects seeking EU passporting or a nominal local presence without operational substance.
• Requires review: custody, fiat balances, lending, staking and investment products. Eligibility depends on the actual model.

Which Regulatory Route Applies?

The service and customer rights determine the route, not the “crypto” label.

Trigger	Route and supervisor	Boundary
Professional intermediation under AMLA Article 2(3), without another licensing trigger	FINMA-recognized SRO membership, supervised by the SRO	AML supervision, not institutional authorization
Qualifying deposits or cryptobased assets under Banking Act Article 1b	FinTech license, FINMA	Restricted asset use and interest payments
Statutory banking activity	Bank license, FINMA	Banking prudential requirements
Professional securities dealing	Securities firm license, FINMA	Securities-specific scope
Qualifying multilateral DLT-securities trading	DLT trading facility license, FINMA	Infrastructure requirements
Portfolio or collective investment management	Applicable manager/fund authorization and product assessment	Institution-specific supervision
Software without regulated activity	No-license analysis	Valid only for the assessed functions

SRO affiliation is not a FINMA license. FINMA-licensed portfolio managers generally have ongoing supervision through a supervisory organization, distinct from an AMLA SRO.

The FinTech license permits public deposits up to CHF 100 million or qualifying cryptobased assets, without investing them or paying interest. Customers must be informed that deposits lack deposit protection.

Which Activities Need Assessment?

• Exchange and brokerage: crypto-to-fiat, crypto-to-crypto, OTC execution and counterparties.
• Payments: virtual asset transfers, merchant settlement and retained balances.
• Custody: key control, customer entitlements, asset allocation and insolvency protection. Key control alone does not determine licensing.
• Boundary cases: stablecoins, token issuance, securities, lending and staking. Non-custodial software and DeFi require analysis of actual control.

FINMA’s token classification classifies tokens by their payment, utility, asset and hybrid functions.

What Can Gofaizen & Sherle Handle?

G&S coordinates the agreed preparation for SRO membership:

• Assessing the business model and preparing the regulatory business case.
• Drafting AML/KYC policies and organizing application documents.
• Supporting submission and communication with the selected SRO.
• Arranging company formation, local recruitment and office setup under the Fully Operational package.
• Assessing suitable banks or EMIs and guiding the account application.

Corporate providers, prospective employees, the SRO and account providers remain responsible for their respective work and decisions. Direct FINMA licensing requires a separately confirmed scope.

How Does the Application Process Work?

1. Document collection and assessment. You provide ownership information, personal documents and the proposed business model. Gofaizen & Sherle reviews the activities and prepares the application checklist.
2. Company and local team setup. Where included, Gofaizen & Sherle coordinates incorporation, corporate documents, recruitment of a local board member and AML officer, and office arrangements.
3. SRO application. Gofaizen & Sherle prepares the AML/KYC policy and application materials, supports submission and handles follow-up communication within the agreed mandate. The SRO decides admission.
4. Banking preparation and application. Gofaizen & Sherle assesses suitable banks or EMIs, organizes supporting evidence and guides the application. The provider makes the account-opening decision.

Management checks the applicable permissions and operational readiness before regulated activities begin.

What Requirements and Documents Apply?

The initial review covers:

• Founders, shareholders, beneficial owners, directors, residence and funding sources.
• Services, customer markets, expected volumes, custody, deposits and payment flows.
• Business plan, ownership structure and organizational chart.
• Corporate documents and, for existing companies, available annual accounts.
• AML/KYC policies, compliance responsibilities and external-auditor arrangements.
• Personal documents for the proposed board member and AML officer.

Depending on the SRO checklist, personal evidence may include identification, proof of address, CVs, criminal-record extracts and declarations. The application must also address local representation, office arrangements and access to an appropriately qualified auditor.

Company form	Share-capital baseline
GmbH	CHF 20,000, fully paid
AG	CHF 100,000 nominal, at least CHF 50,000 paid at formation

Company capital is separate from service fees. Activities requiring institutional authorization may introduce additional financial and organizational requirements.

How Long Should You Allow?

The schedule separates work that Gofaizen & Sherle can prepare from decisions made by external parties.

Stage	Main timing factors
Initial preparation	Complete personal, corporate and business-model information
Company and team setup	Incorporation, candidate availability and office arrangements
SRO application	Dossier completeness, review and follow-up questions
Account opening	Provider eligibility checks and due diligence

Gofaizen & Sherle can prepare a project estimate once the starting position and scope are clear. Recruitment, SRO admission and banking review remain subject to third-party availability and decisions.

What is the Regulatory Framework?

There is no universal crypto license. FINMA’s crypto-services overview maps activities to applicable federal law.

Framework	Main relevance
AMLA	Financial intermediation and due diligence
Banking Act and Ordinance	Deposits, relevant custody and FinTech institutions
FinIA	Securities firms and asset managers
FinMIA and DLT provisions	Trading and market infrastructure
CISA	Collective investment structures

What is Current, and What is Pending?

Reviewed: 14 September 2026.

• Issued guidance: FINMA 01/2026 addresses custody and segregation for relevant institutions, without making every custodian a bank.
• Effective 1 October 2026: revised AMLA and legal-entity transparency legislation introduce changes including a beneficial-ownership register. SIF’s announcement confirms commencement. Applicable transition requirements need assessment.
• Proposed: payment instrument institutions and crypto-institutions remain reform proposals, separate from existing licenses.

Do the Canton and Customer Markets Matter?

Yes. Cantonal administration and taxation sit alongside federal regulation. Overseas customers introduce separate market-access requirements.

Swiss status provides no EU passport. MiCA Article 59 governs authorization, while Article 61 provides a narrow client-initiative exception, not an active marketing route.

What Ongoing Compliance is Required?

Controls depend on activities, scale, risk and supervision:

• Customer and beneficial-owner verification, risk assessment and updated records.
• Sanctions screening, transaction monitoring and qualifying reports to MROS.
• Record retention, training, audits and supervisory reporting.
• Travel Rule procedures and appropriate wallet-control checks.
• Required notifications or approvals for material changes.

SRO rules govern affiliated intermediaries. FINMA’s blockchain-payment guidance explains transfer-information expectations for its supervised institutions. Institutional regimes also impose applicable prudential controls.

What Are the Main Regulatory Risks?

• Operating beyond the assessed scope or adding products without reassessment.
• Breaching AML duties or misleading customers about supervisory status.
• Starting activities requiring authorization before it is granted.

FINMA’s guidelines identify unauthorized activity and false regulatory information as offenses.

How Do You Prepare for Banking?

Gofaizen & Sherle can help assess banks and EMIs against the proposed business model, customer markets and transaction profile, then guide the account application.

Workstream	Preparation
Provider assessment	Compare eligibility and risk appetite with the planned operation
Ownership and funding	Organize beneficial-owner information and source-of-funds and wealth evidence
Business and transactions	Explain account purpose, partners, countries, volumes and payment flows
Application support	Coordinate documents and responses to provider questions

SRO membership does not guarantee an account. The bank or EMI controls acceptance, available services and terms. Any accounting-service connection should be specified separately in the engagement.

How is the Business Taxed?

Tax residence, canton, municipality, services and token classification determine the overall burden.

Tax	Baseline
Federal corporate tax	8.5% of taxable net profit. Tax deductibility affects the effective rate
Cantonal/municipal taxes	Additional profit and capital taxation varies locally
VAT	Standard 8.1% where applicable. Financial-service exclusions require individual analysis
Dividend withholding	Generally 35%, subject to applicable relief/refund conditions

Regulatory status does not create an automatic preferential tax rate.

How Do the Alternatives Compare?

Jurisdiction	Route and market access	Capital and fit
Switzerland	SRO/institutional framework, no MiCA passport	Model-specific, for a planned Swiss operation
EU	MiCA CASP authorization and cross-border procedures	Service-class safeguards, for EU access
Liechtenstein	MiCA through EEA legislation	MiCA safeguards and local substance
UK	Applicable FCA and financial-promotion rules, no MiCA passport	Activity-specific, for UK operations

MiCA safeguards use service-class minimums of EUR 50,000/125,000/150,000 and the higher-of calculation in Article 67, including one quarter of fixed overheads. UK planning must account for the FCA’s new regime from 25 October 2027.

Where Can You Verify Status?

Use the exact entity name in the SRO member search or FINMA authorization database. Confirm unclear results with the relevant body because updates can lag.