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 overviewFINMA authorisation
in Switzerland
Carrying on a regulated financial activity in or from Switzerland needs a licence from the Swiss Financial Market Supervisory Authority. The first decision is which one: bank, securities firm, portfolio manager or trustee, fund institution, or none at all. We confirm the category against the statute, build the authorisation file, and carry the application through to approval, through a Supervisory Organisation where the Financial Institutions Act applies, or to FINMA directly.
At a glance
One licence project, from category to approval.
A prudential authorisation to carry on a regulated activity, distinct from SRO membership, which is an anti-money-laundering affiliation.
- Regulator
- FINMA (FINMASA)
- Main categories
- Bank, securities firm, FinIA, fund, insurance
- Typical timeline
- 4–18 months by category
- Supervision
- FINMA, or an SO under FinIA
- Ongoing
- Audit & supervisory levy
The essentials
What FINMA authorisation is, and who needs it
FINMA authorisation is a prudential licence to carry on a regulated financial activity in or from Switzerland. The Swiss Financial Market Supervisory Authority (FINMA), established under the Financial Market Supervisory Act, grants every licence and supervises the licensed sector. If your business takes public deposits, deals in securities, manages other people’s money, runs a fund or underwrites insurance on a professional basis, you must hold the right FINMA licence before you operate. The main difficulty is rarely the application itself but identifying the correct category at the outset, since the wrong one costs months.
Two activities fall outside
A financial intermediary that only triggers anti-money-laundering duties (a crypto exchange, a payment or money-transmitting business) generally needs SRO membership under the Anti-Money Laundering Act rather than a prudential licence. A firm that trades exclusively its own capital, such as a single-family office, normally needs neither. The boundary is a legal question, not a label, and it is the first thing we settle in writing. Which licence a regulated activity does need (with the capital, supervisor and timeline for each) is set out in the table below, then mapped to your activity in the decision map that follows.
The decision
The FINMA licence categories, side by side
Every Swiss financial licence in one view: the statute it sits under, who supervises it, the minimum capital and the typical time to approval. The categories are mutually exclusive in principle but overlap in practice; mapping an activity to the right category is the decisive step.
| Licence | Statute & supervisor | Minimum capital | Typical timeline |
|---|---|---|---|
| Portfolio managerMost common route | FinIA (SR 954.1) · licensed by FINMA, supervised by an SO | CHF 100,000 | 4–8 months |
| TrusteeFinIA | FinIA (SR 954.1) · licensed by FINMA, supervised by an SO | CHF 100,000 | 4–8 months |
| Manager of collective assetsFinIA | FinIA (SR 954.1) · FINMA | CHF 200,000 | 6–12 months |
| Fund management companyCISA | Collective Investment Schemes Act (SR 951.31) · FINMA | CHF 1,000,000 | 6–18 months |
| Securities firmFinIA | FinIA (SR 954.1) · FINMA | CHF 1,500,000 | 6–18 months |
| FinTech (deposit) licenceBanking Act art. 1b | Banking Act (SR 952.0) · FINMA | CHF 300,000 (min.) | 6–12 months |
| BankBanking Act | Banking Act (SR 952.0) · FINMA | CHF 10,000,000 | 12–18 months |
| Insurance undertakingISA | Insurance Supervision Act (SR 961.01) · FINMA | Solvency-based | 9–18 months |
Most licence-holders must also hold own funds of at least 25% of fixed annual costs, and the FinTech licence caps public deposits at CHF 100 million held without investment or interest. The 2027 reform adds dedicated Payment Instrument Institution and Crypto-Institution categories. See our crypto and digital-assets desk.
Which one fits
Reading your activity onto a category
Four questions resolve most cases. The edges turn on custody, discretion and how clients are solicited, where a written scope assessment is decisive.
Start from the activity, not the product name
What the business actually does with money
- Takes repayable public funds: a bank licence, or the FinTech licence below CHF 100 million held without investment.
- Manages individual client portfolios: a portfolio-manager licence under FinIA, supervised by an SO.
- Sets up or administers trusts: a trustee licence under FinIA, the same SO route.
- Manages collective assets or runs a fund: manager of collective assets, or a fund management company, under CISA.
- Deals, market-makes or executes in securities: a securities-firm licence under FinIA.
- Underwrites insurance: authorisation under the Insurance Supervision Act.
SRO membership instead: AML only
- Crypto exchange, brokerage and transfer
- Payment, e-money and money transmission
- Currency exchange and dealing for third parties
An anti-money-laundering affiliation, not a prudential licence. See SRO membership.
No authorisation needed
- Trading exclusively your own capital
- Pure advice with no handling of client funds
- Technology or operational services that are not financial intermediation
How it runs
From category to approval
A deliverable-driven process. The work is front-loaded into governance and the application file; once that is sound, the supervisory review is comparatively predictable. Per-step timings are indicative and often overlap.
- 1–3 weeks
Category & gap analysis
Written qualification of the activity across the licence categories, including the FinIA-versus-CISA and licence-versus-SRO boundaries, and a gap analysis against the chosen regime.
- 3–6 weeks
Entity, capital & people
Swiss entity and registered seat, paid-in minimum capital, fit-and-proper managers and board, auditor nomination, and the outsourcing and risk architecture.
- 4–10 weeks
Governance & application file
Organisational rules, risk management and internal control, compliance and AML framework, business plan and financial projections, assembled into the authorisation dossier.
- 4–14 months
Filing & supervisory dialogue
Submission through the Supervisory Organisation where FinIA applies, or to FINMA directly; handling of regulator queries through to the authorisation decision.
- Ongoing
Go-live & supervision
Operational integration, the supervisory levy, and the periodic audit cycle run by FINMA or the SO, which we can continue to manage after approval.
Budget
What it costs
There are two layers. The first is official: FINMA, and the Supervisory Organisation where FinIA applies, charge an authorisation fee plus a recurring annual supervisory levy, each against its own published tariff and scaled to the size and complexity of the institution. The second, larger layer is standing up the entity, the minimum capital, the governance and the application file, which varies widely between a portfolio-manager licence and a bank.
Because the range is so category-dependent, we do not publish a single figure. We quote a fixed advisory budget in writing against a confirmed licence category, so the number is settled before any work begins rather than discovered along the way.
Ask for a fixed budget
What you need
What every FINMA file has in common
Categories differ, but the spine of an authorisation is consistent. Each application has to show:
- a Swiss legal entity with the paid-in minimum capital for the category, and adequate own funds;
- fit-and-proper managers and board members with relevant education and experience, and Swiss-resident management where required;
- an organisation appropriate to the activity: risk management, internal control and compliance, kept separate from revenue functions;
- a complete AML framework where the activity is also financial intermediation;
- a licensed audit firm, and a credible business plan with financial projections.
When a FINMA licence is the wrong route
The map above already shows the two off-ramps: SRO membership where the activity only triggers anti-money-laundering duties, and no authorisation at all where you trade purely your own capital or advise without handling client funds. The case that catches firms out is timing: where your crypto or payment model will fall under the 2027 Crypto-Institution or Payment Instrument Institution categories, today’s licence can be an interim step we would structure around from the start. We confirm which of these you are in before you spend on a file you do not need.
Why Goldblum
How we run a FINMA authorisation
The category decision and the supervisory dialogue determine most authorisations. We have handled both since 2014, across the licence and the anti-money-laundering perimeter.
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
Category-first scoping
We settle the licence category against FinIA, CISA, the Banking Act and AMLA before launch, so the route is fixed from the outset, not discovered in the supervisory dialogue.
Ongoing
We stay after approval
We run the relationship with FINMA or the Supervisory Organisation through each audit cycle, and can carry the AML function under mandate. Authorisation is the start of the relationship.
Track record
SRO and FINMA engagements since 2014
Non-confidential mandates from more than a decade of Swiss financial-regulation work, dating back to 2014: SRO affiliations, FINMA and FinIA licensing, and regulatory enquiries across crypto, payments, asset management and token projects.
SRO authorisation · FINMA non-subordination ruling
FinIA licence
SRO authorisation · FINMA non-subordination ruling
SRO authorisation · FINMA non-subordination ruling
SRO authorisation · FINMA non-subordination ruling
SRO affiliation
SRO affiliation
SRO affiliation
SRO affiliation
SRO affiliation
- OTN Blockchain StiftungSwiss foundation · federal authorisation
Listed with each client’s agreement (non-NDA). Engagement details are kept general; specifics are covered by professional confidentiality.
Related
Next in this practice
Portfolio managers
Asset manager licence
The most common Swiss licence since the FinIA transition: authorisation for managers of individual client portfolios, supervised through an SO.
Asset manager licenceAML affiliation
SRO membership
The anti-money-laundering route for crypto, payment and money-service businesses that do not need a prudential licence.
SRO membership
FAQ
FINMA authorisation in Switzerland: FAQ
01Which activities need a FINMA licence?
Carrying on a regulated financial activity in or from Switzerland on a professional basis. That includes taking public deposits (a bank or FinTech licence), dealing in securities (a securities-firm licence), managing individual client portfolios or acting as a professional trustee (a FinIA licence), managing collective assets or running a fund (under the Collective Investment Schemes Act), and underwriting insurance (under the Insurance Supervision Act). Acting only as a financial intermediary for anti-money-laundering purposes (a crypto exchange or payment business) usually needs SRO membership rather than a FINMA licence. Trading exclusively your own funds normally needs neither.
02How long does FINMA authorisation take?
It depends on the category, measured from a complete file rather than the first conversation. A portfolio-manager or trustee licence under the Financial Institutions Act typically takes four to eight months, because the application is reviewed by a Supervisory Organisation before it reaches FINMA. Fund, securities-firm and banking licences take longer: six to eighteen months. The variable is the quality of the application, not the regulator, which is why the full file is built before submission.
03What is the minimum capital for a FINMA licence?
It is set by category, as of June 2026: CHF 100,000 fully paid in for a portfolio manager or trustee under the Financial Institutions Act; CHF 200,000 for a manager of collective assets; CHF 1.5 million for a securities firm; CHF 1 million for a fund management company; CHF 10 million for a bank; and a minimum of CHF 300,000 for the FinTech (deposit) licence, which also caps public funds at CHF 100 million. Most licence-holders must also keep own funds equal to at least a quarter of their fixed annual costs.
04What is the difference between FINMA and a Supervisory Organisation?
FINMA is the federal regulator that grants every licence and supervises banks, securities firms, fund institutions and insurers directly. 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 that reviews the application before FINMA and runs the periodic audits afterwards. An SO is not the same as a Self-Regulatory Organisation (SRO), which handles anti-money-laundering affiliation.
05Do I need a Swiss company and resident directors?
In almost all cases, yes. FINMA authorisation attaches to a Swiss legal entity with genuine substance here: an office, qualified managers and, for most licences, Swiss-resident management. The licence also requires fit-and-proper managers with relevant education and experience, an auditor, and a complete internal-control and risk framework. We incorporate the company, arrange the substance and assemble the governance as part of the same project.
06What changes for crypto and payment firms in 2027?
Following a federal consultation that closed in February 2026, the current FinTech licence is being replaced by two dedicated FINMA categories: a Payment Instrument Institution licence for stablecoin issuers and payment services, and a Crypto-Institution licence for custody, trading and staking. Entry into force is expected in 2027 with a one-year transition. Where an activity will fall under the new categories, we structure now for the incoming regime rather than the old one.
07What does FINMA authorisation cost?
There are two layers. FINMA and, where applicable, the Supervisory Organisation charge an authorisation fee and an annual supervisory levy set against their own tariffs. Separately, standing up the entity, the governance and the application file is the larger first-year cost. It varies widely by licence category. We quote a fixed advisory budget in writing against a confirmed category before any work begins, so the number is settled in advance.
08Can I passport an EU or UK licence into Switzerland?
No. Switzerland is not in the EU or the EEA, so there is no passporting of a foreign banking, MiFID or AIFMD licence. To carry on a regulated activity in or from Switzerland you need the relevant Swiss authorisation. Some cross-border services into Switzerland are possible without a Swiss entity, but client advisers of a foreign institution must usually enrol in the Swiss client-adviser register and meet the conduct rules of the Financial Services Act. We assess whether your model needs a full Swiss licence or fits a narrower cross-border route.
09What is the Financial Services Act and how does it differ from a licence?
The Financial Services Act (FinSA) sets conduct rules (client classification, suitability and appropriateness checks, disclosure and documentation) that apply when you provide financial services to clients. The Financial Institutions Act (FinIA) sets the institutional licence you need to operate at all. They run together: FinIA decides whether you may be authorised, FinSA governs how you must treat clients once you are. A portfolio manager needs the FinIA licence and must also comply with FinSA at the point of sale.
10What happens if I operate without the licence I need?
FINMA can order you to stop the activity, appoint an investigator, freeze assets, publish the breach and, in serious cases, order liquidation. Operating without a required authorisation can also lead to criminal proceedings. Because enforcement reaches the individuals behind the business, not only the company, the safe course is to confirm the licence position before taking client money or marketing the service. Where an activity sits close to a boundary, we obtain that clarity first.
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