Swiss trustee
licence (FinIA)

Acting as a professional trustee in or from Switzerland needs a trustee licence under the Financial Institutions Act, the same route as a portfolio manager, with trust-specific requirements. Switzerland has no domestic trust of its own, but it recognises foreign-law trusts and licenses the trustees who administer them. We build the governance and the application file, arrange the Supervisory Organisation affiliation, and carry the licence through to FINMA approval.

Marcus AltenburgMarcus Altenburg, Managing Partner Published Updated
At a glance

Authorisation to administer trusts professionally.

Licensed by FINMA, supervised by a Supervisory Organisation. Trusts governed by foreign law, recognised in Switzerland since 2007.

Legal basis
FinIA (SR 954.1)
Trust recognition
Hague Convention (since 2007)
Minimum capital
CHF 100,000
Supervision
A Supervisory Organisation (SO)
Typical timeline
4–8 months once the file is ready
How trusts work here
The essentials

What the trustee licence is, and who needs it

A Swiss trustee licence is an authorisation under the Financial Institutions Act to act, on a professional basis, as trustee of trusts — holding and administering trust assets for beneficiaries or a defined purpose. Since the FinIA transition closed on 31 December 2022, professional trustees in or from Switzerland must hold this licence and be supervised by a Supervisory Organisation. The regime mirrors the portfolio-manager licence; what differs is the trust expertise the managers must show and the trust-specific administration the firm must run.

Who needs it

  • independent trust companies administering family or commercial trusts;
  • private-client advisers acting as professional trustee under mandate;
  • foreign trustees relocating or extending their business to Switzerland;
  • fiduciaries adding trustee services to an existing practice.

Who does not

Acting as trustee on a genuinely private, non-commercial basis (for instance for one’s own family without remuneration) is treated differently, though the professional threshold is read strictly. Managing client investment portfolios rather than trusts is the asset-manager licence; running a fund is the Collective Investment Schemes Act. We confirm the boundary in writing before any filing.

The legal frame

Trusts in Switzerland: recognised, not domiciled

The single point that surprises newcomers: Switzerland licenses trustees without having a trust of its own. Three facts explain how the regime fits together.

The instrument

No Swiss trust

Foreign law governs the trust

Switzerland has no domestic trust in its civil law. A trust set up by a Swiss-based trustee is governed by a chosen foreign law, commonly English, Jersey or Guernsey, which sets the trustee’s duties and the beneficiaries’ rights.

The recognition

Hague Convention, 2007

Recognised and enforceable here

Switzerland recognises foreign trusts under the Hague Convention on the Law Applicable to Trusts and on their Recognition, in force since 1 July 2007. A proposal to add a Swiss domestic trust was consulted on but not taken forward.

The supervision

Swiss-licensed trustee

FinIA licence + SO supervision

The trustee, the person administering the trust from Switzerland, is what Swiss law regulates: a FinIA licence from FINMA, ongoing supervision by a Supervisory Organisation, and a full AML framework.

The practical effect: you choose the governing law of the trust for the family or structure, and run it through a Swiss-licensed, supervised trustee, combining a familiar common-law instrument with Swiss stability and oversight.

How it runs

From scoping to FINMA approval

The deliverable-driven path, with the Supervisory Organisation built in. Per-step timings are indicative and often overlap; the SO review sits inside the four-to-eight-month range.

  1. 1–2 weeks

    Scoping & SO selection

    Confirmation that the activity is professional trusteeship under FinIA, choice of the Supervisory Organisation, and a gap analysis against its admission criteria.

  2. 2–4 weeks

    Entity, capital & people

    Swiss entity and seat, the paid-in CHF 100,000 capital, qualified managers with trust experience and their fit-and-proper evidence, and the auditor nomination.

  3. 3–6 weeks

    Governance & AML framework

    Organisational rules, trust-administration procedures, risk management and internal control, the compliance function, and the AML policy suite supervised through the SO.

  4. 3–6 months

    SO review & FINMA decision

    Submission to the Supervisory Organisation, handling of its queries, then transmission to FINMA for the authorisation decision.

  5. 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, FINMA levies its share, and an external audit sits on top each year. The larger first-year cost is standing up the entity, the capital, the trust-administration 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. The value is a file that passes the SO and FINMA the first time, not the lowest filing fee.

Ask for a fixed budget
What you need

What the licence requires

The trustee licence rests on trust expertise and organisation. 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 trust-specific education and experience;
  • trust-administration procedures alongside risk management, internal control and compliance;
  • a complete AML framework supervised through the SO, since a trustee is a financial intermediary;
  • a licensed auditor, professional indemnity cover and a credible business plan.

When this is the wrong licence

Two directions sit elsewhere, as noted above: managing investment portfolios is the asset-manager licence, and a fund is the Collective Investment Schemes Act. The line that actually catches people is the private one. Acting as trustee for your own family looks exempt — but the moment it is remunerated, organised or repeated for others, the professional threshold is met and the FinIA licence applies. We test that threshold honestly before you rely on it, rather than building a file you do not need.

Why Goldblum

What the trustee licence involves

Trustee applications turn on demonstrable trust expertise and clean administration: the detail FINMA and the Supervisory Organisation actually test. We have handled these 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

Trust & FinIA together

We align the governing-law choice for the trust with the Swiss licence requirements from the outset, so the structure and the authorisation fit each other.

Ongoing

We run the AML function

We can act as your external AML officer and manage the annual SO audit, keeping the trustee licence in good standing year after year.

Related

Next in this practice

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 overview
Portfolio managers

Asset manager licence

The same FinIA route for managers of individual client portfolios, the most common Swiss financial licence.

Asset manager 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 trustee licence: FAQ

01Who needs a Swiss trustee licence?
Anyone who acts as a trustee on a professional basis in or from Switzerland, holding or administering separate trust assets for beneficiaries or a defined purpose, for remuneration. Since the transitional period under the Financial Institutions Act ended on 31 December 2022, this requires a FinIA trustee licence from FINMA and supervision by a Supervisory Organisation. Acting as trustee occasionally and without commercial intent is treated differently, but the professional threshold is read strictly.
02Does Switzerland have its own trust law?
No. Switzerland has no domestic law of trusts, but it recognises foreign-law trusts under the Hague Convention on the Law Applicable to Trusts and on their Recognition, in force here since 1 July 2007. A proposal to introduce a Swiss domestic trust was consulted on but not taken forward. So a Swiss-based trustee administers trusts governed by a foreign law (English, Jersey, Guernsey and similar) while being licensed and supervised under Swiss financial-institutions law.
03What is the minimum capital for a trustee?
CHF 100,000, fully paid in, as of June 2026, the same as a portfolio manager under the Financial Institutions Act. The firm must also hold own funds of at least a quarter of its fixed annual costs and carry adequate professional indemnity cover. Trust assets are held in the trust, separate from the trustee's own balance sheet, which is why the capital figure is modest relative to a bank or fund licence.
04How is a trustee supervised in Switzerland?
A trustee is licensed by FINMA but supervised day-to-day by a Supervisory Organisation (SO), a FINMA-authorised body such as AOOS or FINcontrol, which reviews the application before FINMA and runs the periodic audits afterwards, including anti-money-laundering supervision. This is the same regime as for portfolio managers. The SO is not a Self-Regulatory Organisation; the SRO route is for non-licensed intermediaries.
05What does a trustee have to demonstrate?
Fit-and-proper managers with trust-specific education and experience, an organisation appropriate to the trust business (risk management, internal control and compliance) and a full anti-money-laundering framework, since a trustee is a financial intermediary. As a rule two qualified managers direct the business, with a single qualified manager accepted only in justified, low-complexity cases. A licensed auditor and a credible business plan complete the file.
06How long does the trustee licence take?
Four to eight months is typical, measured from a complete file. The application is reviewed by the Supervisory Organisation before it reaches FINMA, so the SO stage is part of the timeline. As with every FINMA file, the duration depends on the quality of the governance and fit-and-proper evidence rather than on the regulator.
07Can a foreign trust company set up in Switzerland?
Yes. Foreign trust companies regularly establish a Swiss licensed trustee. The licence attaches to a Swiss legal entity with genuine substance: an office, qualified trust professionals and, in practice, Swiss-resident management. We incorporate the company, arrange the substance and assemble the application as one project, so the licence rests on a properly constituted Swiss entity.
08Which foreign trust laws does a Swiss trustee administer?
Because Switzerland has no trust of its own, a Swiss trustee administers trusts settled under a foreign governing law and recognised here through the Hague Convention. In practice that is most often English law or one of the common offshore regimes: Jersey, Guernsey, the Isle of Man, the Cayman Islands or the British Virgin Islands. The governing law is chosen in the trust deed; the Swiss licence and supervision sit on top of it. We coordinate with the trust's own-law counsel where the structure is being settled at the same time.
09Must the trustee be a company, or can an individual hold the licence?
In practice the licence is held by a Swiss legal entity that acts as trustee, not by an individual. The firm must, as a rule, have two qualified managers directing the trust business, a compliance and risk organisation, an auditor and the CHF 100,000 capital. An individual could in principle be a single qualified manager in a justified, low-complexity case, but the authorisation and the regulatory capital still attach to the licensed entity, which is why a corporate trustee is the standard structure.
10What ongoing obligations does a licensed trustee have?
After authorisation the Supervisory Organisation conducts periodic, risk-based audits covering prudential compliance and anti-money-laundering. The trustee must keep its qualified managers fit and proper, maintain own funds at a quarter of fixed costs, run the AML framework (risk analysis, KYC on settlors and beneficiaries, monitoring and an AML officer) and notify the SO and FINMA of material changes in advance. The duties of the trustee under the trust's own governing law continue to apply alongside Swiss supervision.

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