In Switzerland, not every crypto activity requires an authorisation from FINMA, the Swiss Financial Market Supervisory Authority. It all depends on what the company does. Holding cryptocurrencies for clients, exchanging them or transferring them first requires membership of a self-regulatory organisation (SRO). Accepting deposits from the public falls under the Fintech licence or the banking licence. Operating a trading platform for tokenised securities requires authorisation as a distributed ledger technology (DLT) trading facility.
This detail page answers a single question: which authorisation for which activity. For the overall picture, token classification and the case of stablecoins, see our page FINMA and cryptocurrencies. Taxation, which lies outside FINMA's remit, is covered in our section crypto regulation and taxation.
Does a crypto activity always require FINMA authorisation?
No: FINMA first asks each company to check two separate things. The first is whether it is subject to the Anti-Money Laundering Act (AMLA). The second is a possible obligation to obtain an authorisation. Both assessments are carried out before the activity starts.
The method is the same for every case. FINMA applies existing law without favouring or penalising blockchain, and assesses a token according to its economic function. It distinguishes three types of tokens: payment, utility and asset. An asset token is treated as a security. This classification then guides the choice of authorisation.
When is membership of a self-regulatory organisation enough?
SRO membership is the first level, and it concerns many crypto players. According to FINMA, anyone who accepts assets belonging to third parties, or helps to invest or transfer them, is subject to the AMLA. Anyone subject to the AMLA must join a self-regulatory organisation.
FINMA cites several typical activities at this first level:
- providing wallets;
- trading by means of virtual currencies such as bitcoin;
- operating as a bureau de change or payment service;
- operating a payment system.
Membership entails due diligence obligations, such as identifying beneficial owners. FINMA and the SROs monitor compliance. A FINMA circular specifies what constitutes financial intermediary activity within the meaning of the AMLA. A supervisory communication of 26 August 2019 also deals with payments on the blockchain.
What does the FINMA Fintech licence allow?
The Fintech licence is an authorisation with relaxed requirements, created by the legislator for innovative financial companies. It is based on Article 1b of the Banking Act (BankA). It allows a company to accept deposits from the public of up to 100 million francs, or crypto-assets.
This licence sets clear limits. The deposits and assets accepted may be neither invested nor bear interest. The institution must be a public limited company, a partnership limited by shares or a limited liability company. It must also carry out its business activity in Switzerland.
For the client, the difference from a bank is significant. If a Fintech institution goes bankrupt, its clients' funds are neither privileged nor covered by deposit protection. Prospective clients must be informed of this. In a report of 16 December 2022, the Federal Council acknowledged the need for action in this area, according to FINMA.
When is a banking or securities firm licence required?
The banking licence and the securities firm licence cover activities that go beyond the relaxed framework. FINMA lists both among the authorisations to be considered on its Fintech page. A model that invests or pays interest on the deposits it receives falls, by definition, outside the scope of the Fintech licence.
Asset tokens point towards the rules on securities trading. Their issuance generally entails a prospectus obligation. The pages consulted do not detail the precise criteria for the securities firm licence for a crypto activity. When faced with an application, FINMA itself assesses whether the activity requires an authorisation and which one is appropriate.
What is a DLT trading facility?
This status is aimed at platforms that trade securities recorded on a distributed ledger. It is governed by the Financial Market Infrastructure Act (FMIA), in Articles 73a et seq. It allows multilateral trading in these securities according to non-discretionary rules.
Authorisation becomes necessary as soon as the platform meets at least one of three conditions:
- it admits retail clients as participants;
- it holds DLT securities in custody according to uniform rules;
- it clears and settles transactions in these securities according to uniform rules.
The formal requirements are strict. The facility must be a legal entity under Swiss law, with its registered office in Switzerland and its effective management in Switzerland. FINMA requires an audit firm review for all these applications, without exception.
Which authorisation for which crypto activity?
| Activity | Applicable framework according to FINMA |
|---|---|
| Wallets, exchange, trading in virtual currencies, payments | Anti-Money Laundering Act and SRO membership |
| Deposits from the public (up to 100 million francs) or crypto-assets, neither invested nor bearing interest | Fintech licence (Art. 1b BankA) |
| Banking activity outside this framework | Banking authorisation |
| Issuance of or trading in asset tokens | Securities trading rules, prospectus; securities firm to be considered |
| Multilateral platform for tokenised securities | DLT trading facility (FMIA) |
| Fund invested in cryptocurrencies | Fund authorisation (collective investment schemes) |
| Payment system backed by a stablecoin | Payment system authorisation (FMIA), on a case-by-case basis |
How does an authorisation application work?
The procedure follows the same pattern for the Fintech licence and for the DLT trading facility. FINMA publishes a practical guide for each. Project owners can present their project to it before submitting a formal application, via the address fintech@finma.ch.
After receiving the file, FINMA designates the staff member in charge and specifies any missing documents. For a Fintech licence, it decides on a case-by-case basis whether an audit report is necessary. The procedure is subject to fees, set by the FINMA Fees Ordinance. Its duration depends on the complexity of the project and the quality of the file.
A start-up must also think about its bank account. On 21 September 2018, the Swiss Bankers Association published a practical guide on opening accounts for blockchain companies. FINMA and the Federal Department of Finance support this initiative.
Is a European MiCA licence valid in Switzerland?
No: a MiCA authorisation, under the European regulation on markets in crypto-assets, does not cover Switzerland. Its passport extends to the countries of the European Economic Area, of which Switzerland is not a member. Thus BingX's MiCA licence, obtained in Austria, covers 29 EEA countries, but not the Swiss market.
What difference does FINMA authorisation make for the client?
An authorisation regulates an institution or a product, not the risk of the asset. The first Swiss-law bitcoin ETF open to the public offers a dated example. On 20 October 2026, FINMA announced the authorisation of this fund. It required custody measures, clear documentation on the risks and the distribution rules of the Financial Services Act (FinSA). It also pointed out that the capital invested can lose a significant part of its value.
Before opening an account, an individual can consult two sections of the FINMA website: "Authorised institutions" and "Warnings". With a Fintech institution, they should bear in mind the absence of deposit protection.
For institutions, regulation weighs on their choices. According to the Swiss Blockchain Survey 2026 by the University of St. Gallen, 46% of the 25 institutions surveyed cite regulatory or compliance requirements as an obstacle to their blockchain offerings. In the third quarter of 2026, 68% of them were already offering a crypto service.
Key figures
- 100 million francs: cap on deposits from the public under a Fintech licence.
- 3 alternative conditions make authorisation as a DLT trading facility necessary.
- 3 types of tokens distinguished by FINMA: payment, utility, asset.
- 29 EEA countries covered by a MiCA passport, excluding Switzerland.
- 46% of the institutions surveyed by the Swiss Blockchain Survey 2026 see regulation as an obstacle.
What we don't know yet
Several points remain open in the sources consulted. FINMA mentions a draft amendment to financial market law to promote innovative business models, without specifying its content or timetable. Its circular on video and online identification is shown as valid until 30 October 2026, with no indication of what will replace it. Finally, the pages consulted give neither the average duration of a procedure nor the amount of the fees.
