Token issuers
Token classification ruling
The taxonomy and ruling for ordinary tokens: the discipline a stablecoin extends into banking, fund and payment law.
Token classificationSwiss stablecoin
issuance & regulation
A stablecoin’s regulatory regime is not a label you pick. It follows from the redemption claim. A fixed-value claim against the issuer looks like a deposit; a managed pool looks like a fund; a bank guarantee can change the picture; and a payment instrument licence is coming. We map the design to a viable regime, structure the claim, reserve and guarantee towards it, and secure the FINMA ruling before launch.
At a glance
The redemption claim decides the regime.
Deposit, fund or payment instrument, structured deliberately, not by accident.
- Fixed redeemable claim
- Deposit (banking) territory
- Bank default guarantee
- Can avoid a full banking licence
- Managed backing pool
- Collective investment
- Coming 2026–2027
- Payment instrument licence (proposed)
- AML
- Holders identified as customers
The essentials
What governs a Swiss stablecoin
Switzerland has no dedicated stablecoin statute. A fiat-referenced stablecoin is regulated according to the rights it gives holders, assessed by FINMA under banking, collective-investment and, once the reform lands, payment-instrument law. The pivot is the redemption claim: a promise to pay a holder a fixed amount on demand is, in substance, a deposit. How that claim and its backing are built decides which regime applies, which is why structuring and legal analysis must run together before issuance.
Who this is for
- issuers of a fiat-referenced payment stablecoin;
- projects building a settlement or payments token on stable value;
- teams that need to know whether they are in banking, fund or payment law;
- issuers preparing for the incoming payment instrument licence.
Not the same as a basic token
A stablecoin is the hard case the classification page flags. It needs its own regime analysis. The AML duties tie to the Travel Rule framework, and the whole sits within financial regulation.
The decision
Deposit, fund or payment instrument
The same coin can fall into very different regimes depending on how the claim and backing are framed. Designing towards one deliberately is the whole game.
| Structure | Regime | Key condition |
|---|---|---|
| Fixed redeemable claim on issuer | Deposit / banking | Banking licence, unless guaranteed |
| Claim covered by bank guarantee | Outside full banking licence | Default guarantee covering holders |
| Share in a managed asset pool | Collective investment | Fund rules & regulated custody |
| Payment-focused issuance | Payment instrument (proposed) | Segregation; reform in force |
None of these is a shortcut: each is a defined regime with real conditions on reserves, custody, guarantees and AML. The work is choosing the one your business model can genuinely satisfy and building the coin to fit it, confirmed by a FINMA ruling before a single token is in circulation.
How it runs
From design to ruling
Front-loaded by necessity: the regime, the reserve and guarantee, the ruling and the AML build all come before issuance, because a stablecoin on the wrong regime cannot be corrected later.
- Stage 1
Regime analysis
Testing the intended redemption claim and backing against banking, fund and payment-instrument law to identify the viable regime.
- Stage 2
Claim & reserve structuring
Designing the redemption mechanics, the reserve, and any bank default guarantee so the coin lands in the chosen regime.
- Stage 3
AML framework
Building holder identification, beneficial-ownership checks, monitoring and the Travel Rule to function for a freely circulating token.
- Stage 4
FINMA ruling
Confirming the classification, guarantee and AML treatment in writing before holders are exposed.
- Ongoing
Operate & convert
Reserve management, reporting and audit, and positioning to move into the payment instrument licence when the reform takes effect.
Budget
What it costs
A stablecoin is among the heavier crypto structurings, because a banking, fund or payment-regime analysis sits beneath it and the AML build for holder identification is substantial. The cost reflects the regime chosen, the reserve and guarantee arrangements, and the compliance function, not a fixed package.
We scope and quote against the specific design. Pricing is on request, and is modest against the cost of issuing on the wrong regime.
Discuss your design
What you need
What an issuance requires
A compliant stablecoin rests on a structure where the promise to holders is genuinely covered and traceable:
- a clearly defined redemption claim, designed towards a viable regime;
- a reserve and any bank guarantee that actually backs that claim;
- regulated custody and segregation appropriate to the regime;
- an AML framework that identifies holders and beneficial owners at scale;
- a FINMA ruling confirming the regime before issuance.
A stablecoin is not a way around banking law
The temptation is to treat a stablecoin as “just a token” and issue it on a light AML wrapper. But a coin redeemable one-for-one against the issuer is, in substance, deposit-taking, and FINMA additionally treats every holder as a customer to be identified. Issuing on the assumption that the token form sidesteps banking and AML law is how a project becomes an unlicensed bank with an unidentifiable customer base. The structure has to choose a real regime and meet it. There is no token-shaped exemption from financial law.
Why Goldblum
How we run a stablecoin issuance
A stablecoin sits at the intersection of banking, fund, payment and AML law. Choosing the regime, structuring the claim and reserve to meet it, and securing the ruling is financial-regulation work of the heavier kind, which is what this desk does.
Regime
The viable one, chosen first
The design tested against banking, fund and payment law before building, so the coin is shaped towards a regime it can actually satisfy.
Backing
Claim and guarantee that hold
The redemption mechanics, reserve and any bank default guarantee structured so the promise to holders is genuinely covered under the chosen regime.
AML at scale
Holders actually identifiable
An AML framework built for a freely circulating token, so holder identification and the Travel Rule function in practice, not just on paper.
Related
The regime around a stablecoin
Custodians · 2027
Crypto custody
Segregation of reserve and client assets, the deposit boundary, and the custody licence arriving with the reform.
Crypto custodyThe wider regime
Financial regulation
FINMA licences, SRO membership and the 2027 categories in full — the practice the crypto desk sits inside.
Financial regulation
FAQ
Stablecoin issuance: FAQ
01How is a stablecoin regulated in Switzerland?
There is no single 'stablecoin law'. How a fiat-referenced stablecoin is regulated depends on the rights it gives holders, above all the redemption claim. A token redeemable for a fixed sum against the issuer typically creates a deposit, which engages banking regulation; a token backed by a managed pool can be a collective investment; and the incoming reform adds a payment instrument licence aimed at stablecoins. The structure determines the regime, so the design and the legal analysis have to happen together, before issuance.
02Why does the redemption claim decide everything?
Because a promise to pay the holder a fixed amount on demand is, in substance, what banking law calls a deposit. If your stablecoin gives each holder a claim to redeem one token for one franc (or dollar, or euro) against the issuer, FINMA will look at it as deposit-taking unless the structure removes that characterisation. Everything else (the reserve, the technology, the marketing) follows from how that claim is framed. Get the redemption mechanics right and the regime is manageable; get them wrong and you are running an unlicensed bank.
03Can I issue a stablecoin without a banking licence?
Sometimes, with the right structure. FINMA has indicated that where a bank provides a default guarantee covering the holders' claims, a stablecoin issuance can avoid a full banking licence, because the depositor protection a bank licence exists to provide is supplied another way. Alternatively, structuring the backing as a collective investment moves it into fund regulation instead. Neither is a loophole; each is a defined regime with its own conditions. We map which one your design can realistically meet before you build it.
04What is the payment instrument licence for stablecoins?
It is a proposed new FINMA category. The Federal Council's October 2025 consultation on revising the Financial Institutions Act would create a payment instrument institution licence aimed at stablecoin issuers and payment businesses, replacing the fintech licence, removing its CHF 100 million deposit cap, and requiring segregation of client funds. It is expected to take effect around 2026–2027. As of June 2026 it is proposed, not in force, so a stablecoin launching now is structured under the existing regime and positioned to move into the new licence when it arrives.
05What AML obligations does a stablecoin issuer have?
Heavy ones, and stricter than many expect. FINMA treats a stablecoin as a means of payment, which means the issuer generally must identify the holders of the token and the beneficial owners behind them. The people holding the stablecoin are treated as the issuer's customers for anti-money-laundering purposes. That is a demanding standard for a token that can circulate freely. Building the issuance so holder identification, monitoring and the Travel Rule actually function at scale is one of the hardest parts of a compliant stablecoin, and central to how we structure it.
06What backing and reserves does a Swiss stablecoin need?
It depends on the regime, but the principle is that the claim holders have must be genuinely covered. Under a deposit or guarantee structure, the reserve and any bank guarantee must actually back the redemption promise; under a collective-investment structure, the pooled assets are managed and held under fund rules. Reserve quality, segregation, custody and the right to redeem all have to line up with the regulatory category. We structure the reserve and guarantee to satisfy the specific regime, not to a generic 'fully backed' claim.
07Stablecoin, deposit, or fund — how is mine classified?
By how the claim and the backing are built. A redeemable fixed-value claim against the issuer points to a deposit; a token representing a share in a managed pool of assets points to a collective investment; a claim covered by a bank's default guarantee can sit outside a full banking licence. The classification is not a label you choose. It follows from the mechanics. The right approach is to design the mechanics deliberately towards a viable regime and confirm it with a FINMA ruling before launch.
08Do I need a FINMA ruling before issuing a stablecoin?
In practice, yes. Given how consequential the classification is (banking, fund or payment regime, each with different licensing), issuing a stablecoin without a written FINMA position is taking an existential risk with the project. A ruling confirms how FINMA views the redemption claim, the guarantee and the AML treatment before holders are exposed. It is the same discipline as a token classification ruling, applied to the harder case of a fiat-referenced coin. We obtain it as part of structuring the issuance.
09Does a Swiss stablecoin passport into the EU?
No. A Swiss authorisation governs issuance in and from Switzerland; it does not give the EU passport that an issuer authorised under the EU's MiCA regime obtains across member states. A Swiss stablecoin can serve Swiss and many international holders, but offering it as a regulated e-money or asset-referenced token into the EU generally needs EU authorisation. We are clear about the perimeter so the distribution plan matches the authorisations actually held.
10How long does it take to launch a compliant stablecoin?
Longer than a basic token, because the structuring is heavier and a banking, fund or payment-regime analysis sits underneath it, alongside the AML build for holder identification. The work is front-loaded: the regime design, the reserve and guarantee structure, the FINMA ruling and the compliance framework. Once those are settled the issuance follows, but they are not steps to rush. A stablecoin that launches on the wrong regime is the costliest mistake in this field. We sequence it so the foundation is right.
11What does Goldblum do on a stablecoin issuance?
We analyse which regime the design can realistically meet, structure the redemption claim, reserve and any bank guarantee towards it, obtain the FINMA ruling, and build the AML framework that holder-identification demands. We then position the structure to convert into the payment instrument licence when the reform takes effect. Because the regimes are banking, fund and payment law rather than a single stablecoin code, this is financial-regulation work, which is the desk it sits on.
Issuing a stablecoin?
Tell us how the coin redeems and what backs it. A partner maps it to a viable regime, structures the claim and reserve, and secures the FINMA ruling before you launch.