Swiss banking &
FinTech licence

Accepting public deposits is, in principle, a banking activity, but not every deposit-holding model needs a full banking licence. The lighter FinTech licence lets a Swiss firm hold up to CHF 100 million of public deposits without lending or investing them. Choosing correctly between the full banking licence, the FinTech licence, and the incoming 2027 payment regime is the decision that shapes everything after it. We confirm which you need, build the prudential file, and carry it through FINMA.

Marcus AltenburgMarcus Altenburg, Managing Partner Published Updated
At a glance

Authorisation to hold public deposits.

A full banking licence, or the lighter FinTech deposit licence, both supervised directly by FINMA.

Legal basis
Banking Act, Art. 1b (FinTech)
FinTech cap
CHF 100m public deposits, not invested
FinTech capital
CHF 300,000 & 3% of deposits
Supervision
FINMA, directly
Reform ahead
Payment-institution regime, 2027
Which licence do you need?
The essentials

Two deposit licences, and which one fits

Accepting public deposits is, in principle, reserved to licensed banks under the Banking Act. But the FinTech licence under Article 1b offers a lighter route: holding up to CHF 100 million of public deposits without lending, investing or paying interest on them. The full banking licence permits lending and investing, with far heavier capital and supervision. The first and most consequential step is choosing correctly between them.

Who needs which

  • deposit-and-lending models: the full banking licence;
  • deposit-holding without lending, under CHF 100m: the FinTech licence;
  • payment and e-money models: today’s rules and the 2027 reform;
  • crypto-asset custody: assessed across banking, FinTech and crypto regimes.

What this is not

Managing client portfolios held at a custodian is the portfolio-manager licence; trading securities is the securities-firm licence; pure payment services may turn on the payment regime. We confirm the right category before any filing.

The boundary

Deposit-taking: which licence, and none

The choice turns on what you do with public deposits: hold them, or lend and invest them. These distinctions decide which licence you need, and whether you need one at all.

Needs a deposit-taking licence

Accepting public deposits on a commercial basis

  • Deposit and lend / invest: the full banking licence, with deposit protection and the heaviest requirements.
  • Hold up to CHF 100m, no lending: the FinTech licence, lighter, no deposit protection, clients informed.
  • Hold crypto-based assets for the public: potentially within the deposit concept, fact-specific.
  • Growing past the cap: plan the transition to a full banking licence in advance.
A different Swiss authorisation
Not deposit-taking
  • Funds segregated and individually attributable to each client
  • Settlement balances held only briefly within strict limits

The deposit boundary is technical: segregation and attribution decide it; confirm before relying on an exemption.

How it runs

From scoping to FINMA approval

A deliverable-driven process, with the licence choice settled first. Per-step timings are indicative and overlap; the full banking licence runs longer than the FinTech licence.

  1. 1–3 weeks

    Scoping & licence choice

    Confirming whether the model is full-banking, FinTech-licence or outside deposit-taking, factoring in the 2027 reform, and sizing the capital.

  2. 3–6 weeks

    Entity, capital & people

    Swiss entity and seat, paid-in capital and own-funds plan, qualified resident managers and their fit-and-proper evidence, and the auditor.

  3. 6–16 weeks

    Prudential & AML framework

    Governance, risk management and internal control, capital-adequacy and own-funds model, IT and operations, client-disclosure, and the full AML suite.

  4. 4–12 months

    FINMA review & decision

    Submission to FINMA, handling its prudential queries, and carrying the file through to the authorisation decision.

  5. Ongoing

    Go-live & supervision cycle

    Operational integration, capital and deposit reporting, and the annual regulatory audit, which we can continue to run.

Budget

What it costs

Two layers, and the choice of licence drives the scale. FINMA charges authorisation and recurring supervisory fees, and a FINMA-recognised audit firm audits the institution each year. The FinTech licence is a lighter build with CHF 300,000 entry capital; the full banking licence is a far larger first-year investment in capital, prudential governance and the application file. The capital itself (CHF 300,000 plus 3% of deposits for FinTech, or CHF 10 million-plus for a bank) sits behind that.

We quote a fixed advisory budget in writing against a confirmed scope, so the number is settled before any work begins.

Ask for a fixed budget
What you need

What the licences require

Both deposit licences rest on capital, organisation and people; the depth differs with the licence. To be authorised you need:

  • a Swiss legal entity with the right capital: CHF 300,000 and 3% of deposits for FinTech, CHF 10 million-plus for a bank;
  • qualified resident managers, fit and proper, and adequate governance;
  • risk management, compliance and internal control to the licence’s standard;
  • a complete AML framework supervised within FINMA’s direct supervision;
  • a FINMA-recognised auditor, the IT and operations to run the model, and the required client disclosures.

The FinTech licence is not a free pass: mind the cap and the disclosure

Two things catch FinTech-licence businesses. First, the CHF 100 million cap is a hard limit: a model that succeeds and grows past it needs a full banking licence, which cannot be obtained at short notice, so the transition must be planned long before the cap is reached, not when deposits hit it. Second, deposits under a FinTech licence are not protected by deposit protection, and clients must be clearly informed; getting that disclosure wrong is both a compliance failure and a reputational risk. And with the 2027 reform set to abolish the FinTech licence entirely, today’s choice has to be made with the coming regime in view. We build the cap transition, the disclosures and the reform into the strategy from the start.

Why Goldblum

The deposit licence, and what it involves

Most deposit-licence projects are won or lost on the licence choice and the prudential organisation behind it, not the capital figure. 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.

Right licence

The choice settled first

We confirm full-banking versus FinTech versus the 2027 payment regime in writing at scoping, so you build the licence you need rather than the one you assumed.

Ongoing

We carry the supervision

We can run the ongoing compliance and AML function and manage the annual FINMA-recognised audit, keeping the licence in good standing year after year.

Related

Next in this practice

Payments

Payment & e-money licence

Authorisation for payment and e-money businesses today, and the path to the 2027 Payment Instrument Institution licence.

Payment & e-money licence
Securities firms

Securities firm licence

The FinIA authorisation for dealing, market-making and underwriting securities, supervised directly by FINMA.

Securities firm licence
Overview

FINMA authorisation

All the Swiss licence categories in one place, and how to tell which one your activity needs.

FINMA authorisation
FAQ

Swiss banking & FinTech licence: FAQ

01When do I need a Swiss banking licence?
Whenever you accept deposits from the public on a commercial basis and use them: most clearly, take deposits and lend or invest them. Accepting public deposits is, in principle, a banking activity reserved to licensed banks under the Banking Act, with a full FINMA licence and direct FINMA supervision. The full banking licence is a heavy authorisation, with substantial capital, governance and ongoing requirements. But not every deposit-taking model needs the full licence: the lighter FinTech deposit licence covers holding public deposits up to a cap without lending or investing them. We confirm whether your model is full-banking, FinTech-licence, or outside deposit-taking altogether before any filing.
02What is the FinTech licence and what does it allow?
The FinTech licence (sometimes called the “banking licence light”, under Article 1b of the Banking Act) lets a firm accept public deposits of up to CHF 100 million, provided it neither invests those deposits nor pays interest on them. It is designed for innovative deposit-holding business models that do not engage in the maturity-transformation that defines banking. The trade-off is lighter regulation in return for not lending or investing the funds, and a key consumer point: deposits under a FinTech licence are not covered by deposit protection, and clients must be told. We assess whether your model fits inside the FinTech licence or genuinely needs the full banking licence.
03What is the minimum capital for the FinTech licence?
CHF 300,000, and at least 3% of the public deposits held, as of June 2026, whichever is higher in practice as deposits grow. The minimum capital floor is CHF 300,000, but because own funds must also be at least 3% of the public deposits held, a firm approaching the CHF 100 million deposit cap needs materially more capital than the floor. The FinTech-licence holder must also be a Swiss company (a company limited by shares, a corporation with unlimited partners, or a limited liability company) with its registered office and business in Switzerland. We size the real capital requirement against your expected deposit volume, not just the entry floor.
04How much capital does a full banking licence need?
Substantially more than the FinTech licence: a full bank’s minimum fully paid-in capital is in the order of CHF 10 million, and the ongoing capital-adequacy requirements scale well beyond that with the balance sheet and risk profile. The full banking licence is a different order of authorisation from the FinTech licence: it permits lending and investing of deposits, carries the heaviest prudential requirements, and comes with deposit protection. The capital figure is only the entry point; the substance is the prudential organisation, risk management and governance that supervising a deposit-taking, lending institution demands. We size the real requirement against the business model rather than quoting a floor.
05What is the CHF 100 million cap, and what happens at it?
The FinTech licence permits public deposits up to CHF 100 million. Cross that threshold and the FinTech licence no longer covers the activity: the firm needs the full banking licence, unless FINMA grants an exception in a specific case. The cap is the defining limit of the lighter regime: it lets a deposit-holding business operate under lighter regulation up to a meaningful scale, but a successful business that grows past CHF 100 million has to plan its transition to a full banking licence well in advance, because that authorisation cannot be obtained overnight. We build the growth and transition path into the licensing strategy, so hitting the cap is a planned step rather than a sudden problem.
06What is changing with the 2027 reform?
The Federal Council has proposed abolishing the FinTech licence and replacing it with two new directly-FINMA-supervised categories: a Payment Instrument Institution licence and a Crypto-Institution licence. The proposal, out for consultation from October 2025 into 2026, with the new framework expected to take effect around late 2026 or 2027, would remove the CHF 100 million deposit cap for the new payment category, require segregation of client funds, and shift supervision of these models directly to FINMA. For a deposit-holding or payment business, this materially changes the licensing options and the right strategy. We track the reform and factor it into the licensing decision, so today’s application is built with the coming regime in view.
07How is a deposit-taking institution supervised?
Directly by FINMA. Both the full banking licence and the FinTech licence put the institution under FINMA’s direct prudential supervision: the full bank more heavily, the FinTech-licence holder more lightly, but neither through a Supervisory Organisation or SRO. That means ongoing capital and reporting requirements, risk management and internal control, an audit by a FINMA-recognised audit firm, the full AML framework, and advance notification of material changes. The licence is a continuing supervisory relationship, with the depth set by which licence you hold. We build the file and governance to the right standard for the licence you actually need.
08How long does a banking or FinTech licence take?
The FinTech licence is the faster of the two, often in the order of six to twelve months from a complete file, while a full banking licence is a longer, heavier project, frequently well over a year, because the prudential bar and FINMA’s scrutiny are higher. In both cases the timeline is driven by the completeness of the file: the capital and own-funds model, the governance and risk framework, the IT and operational set-up, the fit-and-proper evidence, and the AML framework. A coherent dossier that answers the prudential questions up front is what compresses the review. We build the full file before submission rather than filing into gaps.
09Does crypto-asset custody fall under these licences?
It can, depending on how the assets are held. Holding crypto-based assets for the public can fall within the deposit concept and so within the FinTech or banking regime, particularly where the assets are not segregated and individually attributable to clients; properly segregated custody can fall outside deposit-taking. The treatment is fact-specific and is also changing under the proposed Crypto-Institution regime. Because the line is technical and shifting, a crypto business should get the characterisation right before building. We assess where a crypto-asset model sits across the banking, FinTech and incoming crypto-institution regimes, and coordinate with our <a href="/crypto/">crypto desk</a>.
10Can a foreign group establish a Swiss bank or FinTech institution?
Yes. The licence attaches to a Swiss legal entity with real substance, capital, qualified resident management and governance on the ground, and FINMA examines that entity, its people and its owners, together with any group and consolidated-supervision dimension. Foreign banking groups establish Swiss subsidiaries, and foreign-owned firms obtain the FinTech licence; what matters is the Swiss entity and its organisation, not the nationality of the owners, alongside the fitness of the controllers and the adequacy of home-country supervision where relevant. We incorporate the entity, arrange the substance and capital, build the file, and handle the cross-border and group questions as one project.
11Can Goldblum run the banking or FinTech licence project?
Yes, in full, and starting with the question that matters most: which licence the activity actually needs. We confirm whether the model is full-banking, FinTech-licence, or outside deposit-taking, factor in the 2027 reform, incorporate the Swiss entity and arrange the capital, build the prudential governance, risk and AML frameworks, and carry the application through FINMA to approval. After authorisation we can run the ongoing compliance and AML function and manage the annual audit. The deposit-taking licences are among the heaviest Swiss authorisations, and the value is getting the licence choice and the prudential file right, the work we have done since 2014.

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