Overview
Financial Regulation & Licensing
The full practice: every FINMA licence, SRO membership and AML in one place, and how to tell which you need.
Financial Regulation overviewSwiss asset manager
licence (FinIA)
If you manage individual client portfolios on a commercial basis in or from Switzerland, you need a portfolio-manager licence under the Financial Institutions Act, the most common Swiss financial licence since the FinIA transition closed at the end of 2022. It is granted by FINMA and supervised by a Supervisory Organisation. We build the governance and the application file, arrange the SO affiliation, and carry the licence through to approval.
At a glance
Authorisation to manage other people’s portfolios.
Licensed by FINMA, supervised by a Supervisory Organisation: client assets stay with a custodian, not with you.
- Legal basis
- FinIA (SR 954.1)
- Who it applies to
- Managers of individual client assets
- Minimum capital
- CHF 100,000
- Supervision
- A Supervisory Organisation (SO)
- Typical timeline
- 4–8 months once the file is ready
The essentials
What the asset manager licence is, and who needs it
A Swiss asset manager licence (formally a portfolio-manager authorisation under the Financial Institutions Act) lets a firm manage individual client portfolios on a discretionary basis. Since the FinIA transition closed on 31 December 2022, every manager of third-party individual assets must hold this licence and be supervised by a Supervisory Organisation. Carrying on the activity without it is an unlawful regulated activity and exposes the principals to FINMA enforcement. Defining the licence is straightforward; the substantive work is meeting the fit-and-proper and organisational requirements behind it.
Who needs it
- independent asset managers exercising discretion over client portfolios;
- external managers acting under mandate for private or institutional clients;
- family offices that manage assets for parties beyond a single family;
- managers relocating to Switzerland to run existing client books.
Who does not
Managing only your own capital, as a genuine single-family office, falls outside the licence. Managing collective assets or running a fund is a different regime under the Collective Investment Schemes Act (see fund & collective investment licence). Pure investment advice without discretion does not need a FinIA licence, but may require entry in the FinSA client-adviser register. We confirm which side of each line you sit on before any filing.
The boundary
Portfolio management: in scope, and out
The licence turns on one thing: discretion over someone else’s individual assets. These distinctions decide whether you need a FinIA portfolio-manager licence, a different authorisation, or none.
Needs a FinIA portfolio-manager licence
Discretionary management of individual client assets
- Discretionary mandates: you decide and execute trades for a client under a management agreement.
- Multiple clients: managing assets for parties beyond a single family, on a commercial basis.
- Assets at a custodian: you direct accounts held in the client’s name at a bank or custodian.
- Cross-border into Switzerland: managing from a Swiss seat, whatever the clients’ residence.
A different Swiss authorisation
- Managing collective assets or a fund: CISA (fund licence)
- Acting as a professional trustee: FinIA (trustee licence)
- Advice only, no discretion: FinSA client-adviser register
No licence needed
- Managing exclusively your own capital
- A genuine single-family office, family members only
The single-family-office boundary is read strictly. Confirm it before relying on it.
How it runs
From scoping to FINMA approval
A deliverable-driven process, with the Supervisory Organisation built into the path. Per-step timings are indicative and often overlap; the SO review sits inside the four-to-eight-month range.
- 1–2 weeks
Scoping & SO selection
Confirmation that the activity is portfolio management under FinIA, choice of the Supervisory Organisation, and a gap analysis against its admission criteria.
- 2–4 weeks
Entity, capital & people
Swiss entity and seat, the paid-in CHF 100,000 capital, the qualified managers and their fit-and-proper evidence, and the auditor nomination.
- 3–6 weeks
Governance & AML framework
Organisational rules, risk management and internal control separate from portfolio decisions, the compliance function, and the full AML policy suite supervised through the SO.
- 3–6 months
SO review & FINMA decision
Submission to the Supervisory Organisation, handling of its queries, then transmission to FINMA for the authorisation decision.
- Ongoing
Go-live & audit cycle
Operational integration and the periodic SO audit, including AML, which we can continue to run for you after approval.
Budget
What it costs
Two layers, as with any FINMA authorisation. The Supervisory Organisation charges an admission fee and a recurring annual supervisory fee against its own tariff, and FINMA levies its share; an external audit sits on top each year. The larger first-year cost is standing up the entity, the capital, the governance and the application file.
We quote a fixed advisory budget in writing against a confirmed scope, so the number is settled before any work begins. We do not compete on being the cheapest filing route; the value is a file that passes the SO and FINMA the first time.
Ask for a fixed budget
What you need
What the licence requires
The portfolio-manager licence rests on people and organisation as much as capital. To be admitted you need:
- a Swiss legal entity with CHF 100,000 paid-in capital and own funds of at least a quarter of fixed costs;
- as a rule two qualified managers, fit and proper, with relevant education and experience;
- risk management, internal control and compliance kept separate from portfolio decisions;
- a complete AML framework (risk analysis, KYC, monitoring and an AML officer) supervised through the SO;
- a licensed auditor, professional indemnity cover, and a credible business plan.
When this is the wrong licence
The scope map above lists the off-ramps: collective assets to CISA, trusteeship to its own FinIA licence, advice-only to the register, own money to nothing. Two of them trip firms up. The single-family-office exemption is read strictly: manage assets for anyone outside the family on a commercial basis and you are back inside the licence. And pure advice without discretion escapes FinIA but may still require entry in the FinSA client-adviser register: “no licence” is not the same as “no registration”. We place you on the right side of each line before you build a file.
Why Goldblum
How we run the FinIA licence
Most asset-manager applications fail on organisation and fit-and-proper detail rather than capital. That is the part we have handled since 2014.
10 yrs
Recognised by IFLR1000
IFLR1000, a leading international directory of financial and corporate practices, has recognised us for a decade for banking, finance and regulatory work.
Day one
SO-ready from the outset
We build the file to the Supervisory Organisation’s criteria from day one, so the review is a confirmation rather than a renegotiation.
Ongoing
We run the AML function
We can act as your external AML officer and manage the annual SO audit, keeping the licence in good standing year after year.
Related
Next in this practice
Trustees
Trustee licence
The same FinIA route for professional trustees who set up or administer trusts in or from Switzerland, with trust-specific requirements.
Trustee licenceOverview
FINMA authorisation
All the Swiss licence categories in one place, and how to tell which one your activity needs.
FINMA authorisation
FAQ
Swiss asset manager licence: FAQ
01Who needs a Swiss asset manager licence?
Anyone who manages individual client portfolios on a commercial basis in or from Switzerland, exercising discretion over third-party assets under a mandate. Since the transitional period under the Financial Institutions Act ended on 31 December 2022, this requires a FinIA portfolio-manager licence from FINMA and supervision by a Supervisory Organisation. Managing only your own capital, or managing collective assets and funds, falls under different rules.
02What is the minimum capital for a portfolio manager?
CHF 100,000, fully paid in, as of June 2026. In addition, the firm must hold own funds equal to at least a quarter of its fixed annual costs, and have adequate guarantees or professional indemnity cover. The capital requirement is modest by FINMA standards because the portfolio manager does not hold client assets in its own name: assets stay with a custodian bank.
03What is a Supervisory Organisation, and why do I need one?
Portfolio managers and trustees are licensed by FINMA but supervised day-to-day by a Supervisory Organisation (SO), a separate FINMA-authorised body such as AOOS or FINcontrol. The SO reviews your application before it reaches FINMA, then conducts your ongoing audits, including anti-money-laundering supervision. You join an SO as part of the licensing project; it is not the same as a Self-Regulatory Organisation, which handles AML affiliation for non-licensed intermediaries.
04How many qualified managers do I need?
As a rule, two qualified managers who direct the business, each with the relevant education and, typically, at least five years of experience in asset management plus recognised training. A single qualified manager can be accepted in justified cases (usually a small operation with low complexity), but this is the exception. The managers must be fit and proper, and the firm needs an appropriate risk-management and compliance organisation kept separate from portfolio decisions.
05How long does the asset manager licence take?
Four to eight months is typical, measured from a complete file. The application runs through the Supervisory Organisation before FINMA, so the SO review is part of the timeline. The variable is the quality of the file (governance, risk management, the business plan and the fit-and-proper evidence) rather than the regulator, which is why the full dossier is built before submission.
06Do I have to handle anti-money-laundering separately?
No separate SRO membership is needed. A portfolio manager is a financial intermediary, but because it is supervised by a Supervisory Organisation, the SO also carries out its anti-money-laundering supervision under the Anti-Money Laundering Act. You still need a full AML framework (risk analysis, KYC, monitoring and an AML officer), but it is audited through the SO, not a separate SRO.
07Can a foreign asset manager get licensed in Switzerland?
Yes. The licence attaches to a Swiss legal entity with real substance: an office, qualified managers and, in practice, Swiss-resident management. Foreign-owned managers regularly obtain the FinIA licence; what matters is the Swiss entity, the qualified people on the ground and the governance, not the nationality of the owners. We incorporate the company, arrange the substance and assemble the file as one project.
08What is the difference between a portfolio manager and a manager of collective assets?
A portfolio manager manages individual client mandates (separate accounts under a power of attorney) and needs CHF 100,000 in capital under the Financial Institutions Act. A manager of collective assets manages pooled vehicles, such as a fund or the assets of a pension fund, and needs CHF 200,000 under the same Act, with a heavier organisation. Larger portfolio managers can cross into the collective-assets category once they manage scheme assets above the statutory thresholds. We confirm which category your book falls into before filing, because the wrong one means the wrong licence.
09Can a portfolio manager hold client money?
No. A FinIA portfolio manager exercises discretion over assets that remain with a custodian bank in the client's name; it never takes the assets onto its own balance sheet. That separation is why the capital requirement is CHF 100,000 rather than the far higher figures for a bank or securities firm. Holding client deposits would be a different, deposit-taking activity requiring a banking or FinTech licence.
10What ongoing obligations apply once the licence is granted?
The licence is the start, not the finish. The Supervisory Organisation runs periodic audits (risk-based, with the interval set by your profile) covering prudential compliance and anti-money-laundering. You must keep two fit-and-proper qualified managers, maintain own funds at a quarter of fixed costs, keep the compliance and risk functions staffed, and report material changes in ownership, management or business model to the SO and FINMA in advance. We can carry the ongoing compliance calendar after the licence is in place.
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