Crypto License Switzerland

Switzerland has no single crypto licence. SRO membership covers most payment and exchange services. FINMA licences cover deposits, securities and trading.

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Switzerland and Crypto Compliance

FINMA, the Swiss Financial Market Supervisory Authority, applies existing financial market law to crypto activities. The authorisation you need depends on what your business does and which assets it handles.

MiCA does not apply in Switzerland. Swiss firms still have to meet Swiss AML rules, and those that actively serve EU clients should check whether MiCA applies to that activity. See our MiCA guide for the EU framework.

What Is a CASP License in Switzerland?

Switzerland does not issue a CASP licence the way EU member states do under MiCA, so searching for one leads nowhere. FINMA treats a business that only moves or exchanges crypto-assets for clients as a financial intermediary under anti-money laundering law. A business that holds client deposits, trades securities or runs a trading venue needs a FINMA licence.

Switzerland EU (MiCA)
Licence label None. Activity-based: SRO membership or a FINMA licence CASP authorisation
Authority FINMA and recognised SROs National competent authority
Minimum capital By route: none for SRO, CHF 300,000 floor (FinTech) up to CHF 10 million (bank) EUR 50,000, 125,000 or 150,000 by service class
Cross-border access A Swiss authorisation does not give EU market access Passport across the EEA
Review time No fixed timeline 25 working days for the completeness check, 40 working days to decide (Art. 63)

You are likely to need SRO membership or a FINMA licence if your company:

  • Stores or manages crypto assets (custody)
  • Runs a trading platform or crypto exchange
  • Offers fiat-to-crypto or crypto-to-crypto exchange
  • Executes orders on behalf of clients
  • Provides crypto payments or investment advice

Crypto License Types in Switzerland

Confirm the classification with FINMA before you build. FINMA publishes its crypto guidance documents on its website.

Route What it covers Legal basis Minimum capital
SRO membership AML supervision of financial intermediaries that FINMA does not supervise prudentially, including many crypto providers. Not a FINMA licence. Anti-Money Laundering Act No licence capital rule
FinTech licence Public deposits of up to CHF 100 million that are not invested and do not earn interest, or collective custody of crypto-based assets. Banking Act, Art. 1b 3% of deposits, at least CHF 300,000
Securities firm Securities dealing: client dealers, own-account dealers and market makers, plus organised trading facilities. Financial Institutions Act CHF 1.5 million, fully paid up
Bank Deposit-taking and banking business beyond the FinTech limits. Banking Act CHF 10 million, fully paid up
DLT trading facility Multilateral trading of DLT securities. Financial Market Infrastructure Act, Art. 73a ff. Set by licence type

FINMA licensed its first DLT trading facility, BX Digital AG, on 18 March 2025. BX Digital applied for a small facility, which carries certain regulatory relief and size limits.

What Is Changing in 2026 and 2027

The Federal Council opened a consultation on 22 October 2025 to replace the FinTech licence with a payment instrument institution licence and to add a crypto-institution licence. The proposed crypto-institution licence would cover custody (including staking), customer trading and crypto exchange services. Licensed banks and securities firms would not need a separate crypto-institution licence. The consultation closed on 6 February 2026. The Federal Council planned to send its dispatch to Parliament in the second half of 2026 at the earliest. As of 28 October 2026 we found no adopted dispatch or law, so check the Federal Council’s site for the current status. Law firm commentary expects entry into force in 2027 at the earliest.

Both new categories would sit under direct FINMA supervision. That would move most custodial wallet and customer trading providers that are now supervised by an SRO. The proposal would also remove the CHF 100 million cap on client funds. The consultation draft proposes a one-year transition after entry into force. This is a proposal, not law. Until a law is enacted, nothing changes for existing SRO members or FinTech licence holders.

How FINMA Classifies Tokens

FINMA sorts tokens by economic function, and the category decides which rules apply. Hybrid forms are possible.

  • Payment tokens: cryptocurrencies with no other function. FINMA does not treat them as securities but requires compliance with anti-money laundering rules.
  • Utility tokens: tokens that give access to an application or service. They are not securities if their sole purpose is that access and it works when the token is issued. If a utility token works wholly or partly as an investment, FINMA treats it as a security.
  • Asset tokens: tokens that represent assets such as shares, income streams, or dividend or interest entitlements. FINMA regards them as securities, so securities trading rules and prospectus requirements apply.
  • Hybrid tokens: tokens that combine functions. A utility token widely used as a means of payment, for example, is subject to anti-money laundering rules.

Stablecoins, Staking and Custody in Switzerland

Stablecoins

FINMA Guidance 06/2024, published on 26 July 2024, covers the risks for stablecoin issuers and for banks that provide guarantees. A default guarantee from a bank can take the issuer outside the deposit rules, so it does not need a banking licence, but the guarantee must meet FINMA’s minimum requirements. FINMA also expects the identity of every stablecoin holder to be verified, by the issuer or a supervised intermediary, and does not allow anonymous transfers. The proposed payment instrument institution licence would regulate issuance directly. Stablecoin compliance tools track token and stablecoin activity.

Staking

FINMA Guidance 08/2023, published on 20 December 2023, states FINMA’s current assessment that staked crypto-assets should be separated from a bankrupt provider’s estate and returned to custody customers, while the legal position awaits legislation or case law. FINMA names three risks providers should explain to customers: technical risk such as slashing, counterparty risk in bankruptcy, and market risk from lock-up or exit periods. Staking does not trigger a capital requirement for a supervised institution that has put risk-mitigating measures in place and informed customers.

Custody

FINMA Guidance 01/2026, published on 12 January 2026, applies to FINMA-supervised institutions that hold crypto-based assets or offer related services, including banks, securities firms, portfolio managers and collective investment schemes. Customers’ assets must be held so that they are protected in the custodian’s bankruptcy. A custodian may delegate to a foreign provider only if that provider is subject to equivalent prudential supervision and foreign law gives comparable bankruptcy protection. The supervised institution stays fully responsible for the custody structure.

How to Apply for a Crypto License in Switzerland

The steps differ by licence. The outline below follows FINMA’s published process for bank and securities firm licences. FINMA publishes separate guidance for the FinTech licence and the DLT trading facility.

  1. Define your activity and choose the route: SRO membership or a FINMA licence.
  2. Present the project to FINMA before applying. For banks and securities firms, send a project presentation by email to authorization@finma.ch. FINMA decides whether a meeting is appropriate, and the assessment of a licensing project is subject to a fee.
  3. Complete the application forms on FINMA’s survey and application platform (EHP). The forms list the information and documents required.
  4. Submit the application. You may use specialised lawyers, consultants or recognised audit firms to help, but FINMA does not make this compulsory. FINMA then tells you which staff member handles the case.
  5. Wait for FINMA’s assessment, which runs in dialogue with you. FINMA sets no fixed timeline: duration depends on the licence type, the quality and complexity of the application and how quickly foreign supervisory authorities respond.

Key Requirements for Crypto Businesses in Switzerland

To operate a crypto business in Switzerland, you must:

  • Hold the right authorisation: SRO membership or, where the activity requires it, a FINMA licence
  • Set up the structure your licence needs. The FinTech licence requires a registered office and effective management in Switzerland
  • Meet the capital requirements of your licence category
  • Run AML and KYC programmes under Swiss law, with the due diligence duties set out below
  • Apply the Travel Rule: originator and beneficiary information must travel with payments. For FINMA-supervised institutions, FINMA Guidance 02/2019 (26 August 2019) applies this to blockchain transfers. They may send tokens only to external wallets of their own verified customers and receive tokens only from them. They must prove that an external wallet belongs to the client using suitable technical means, and a third-party wallet owner must be onboarded as a client
  • Monitor transactions for suspicious activity

AML and KYC Duties for Swiss Crypto Businesses

All financial intermediaries in Switzerland, FINMA-licensed or SRO-affiliated, carry the same core customer due diligence duties:

  • Verify the identity of the contracting party and identify the beneficial owner
  • Clarify the background and purpose of unusual transactions, and of any transaction with signs of criminal origin or terrorist financing
  • Apply enhanced scrutiny to higher-risk relationships, such as those involving high-risk countries or politically exposed persons
  • Maintain internal controls: internal directives, staff training and inspections
  • Report to the Money Laundering Reporting Office (MROS) where there are reasonable grounds to suspect money laundering

FINMA lowered the client identification threshold for crypto exchange transactions from CHF 5,000 to CHF 1,000, effective 1 January 2021.

How Scorechain Supports Swiss Crypto Compliance

Scorechain gives Swiss crypto companies AML and risk monitoring tools for domestic and cross-border flows. The table shows what the tools cover and what stays with your team.

Swiss duty What Scorechain provides What stays with you
Risk checks on wallets and transactions Wallet screening, transaction monitoring and risk scores Setting thresholds and deciding whether to proceed
Clarifying unusual transactions KYA and KYT reports, and case reports with an audit trail Documenting the clarification and the decision
Payment information for crypto transfers Travel Rule API, routed through partner infrastructure Customer identification and proof of wallet ownership
Sanctions exposure Free API checking OFAC, OFSI, MOFA and NBCTF lists Swiss sanctions list checks, which the API does not include
Suspicion reporting Case reports you can export for internal records Your MLRO’s report to MROS

Crypto Transaction Monitoring

Transaction monitoring lets you build alert scenarios from transaction direction, amount and triggered risk indicators. Monitoring runs in real time across 25+ blockchains, with risk scores on addresses and transactions.

Travel Rule Support

The Travel Rule API gives one endpoint to exchange originator and beneficiary data through partner infrastructure, and Scorechain works with Travel Rule partners such as Notabene and CryptoSwift. Customer identification stays in your own KYC process, and the API does not guarantee regulatory approval.

Blockchain Risk Analytics and KYT

KYT and KYA reports show the risk indicators, entities and exposure behind an address or transaction, including exposure to darknet markets and scams. KYA reports export as PDF or CSV.

Sanctions and Wallet Screening

Wallet screening identifies exposure to sanctioned, illicit and high-risk wallets. The free Sanctions Screening API checks addresses against OFAC, OFSI, MOFA and NBCTF lists. For transfers with external wallets, screening gives the risk view on the counterparty address, while proof of ownership remains a separate step in your onboarding. Scorechain flags the risk so your team decides whether to proceed.

FINMA and International Crypto Regulations

Scorechain has supported more than 200 organisations with AML compliance, blockchain analytics and regulatory risk management. Swiss firms that actively serve EU clients should check whether MiCA applies to them, because an authorised CASP needs a registered office and effective management in the EU.

To see wallet screening, transaction monitoring and KYT reports run on your own Swiss flows, book a demo with the Scorechain team.

Frequently Asked Questions

Does Switzerland require a CASP license like the EU?

No. Switzerland has no CASP licence and MiCA does not apply. Crypto firms need the authorisation that fits their activity: SRO membership as a financial intermediary, or a FINMA licence such as a FinTech, bank, securities firm or DLT trading facility licence. A crypto-institution licence is proposed but not in force.

Do I need a FINMA licence to run a crypto exchange in Switzerland?

It depends on the model. Exchange activity falls under anti-money laundering rules, which means SRO membership as a baseline. Holding client deposits can require a FinTech or bank licence, and operating a trading facility can require a securities firm or DLT trading facility licence. Confirm the classification with FINMA before launch.

What is the minimum capital for a Swiss crypto licence?

There is no single figure. The FinTech licence needs 3% of deposits and at least CHF 300,000, a securities firm needs CHF 1.5 million fully paid up, and a bank needs CHF 10 million fully paid up. SRO membership carries no licence capital.

How long does FINMA licensing take?

FINMA gives no fixed timeline. Duration depends on the licence type, the quality and complexity of the application and how quickly foreign supervisory authorities respond.

How does FINMA classify crypto tokens?

FINMA distinguishes payment, utility and asset tokens, and hybrids of these. Payment tokens fall under anti-money laundering rules, asset tokens are treated as securities, and utility tokens are securities only if they work partly or wholly as an investment.

Are stablecoin issuers licensed in Switzerland?

Issuance is not yet covered by a dedicated licence. Many issuers rely on bank default guarantees under FINMA Guidance 06/2024. The proposed payment instrument institution licence would allow issuance of a defined type of stablecoin under special obligations.

Can Swiss companies serve EU customers under MiCA?

Not on a Swiss authorisation alone. A Swiss licence is not among the entities MiCA lists for providing crypto-asset services in the EU, and an authorised CASP needs a registered office in an EU Member State. Under Article 59, the CASP also needs its place of effective management in the EU and at least one director resident in the EU. Firms that actively serve EU clients should take legal advice on EU authorisation.

What happens if I fail to comply with FINMA or SRO rules?

Knowingly carrying on an activity that requires authorisation, including SRO membership, without it is an offence under Article 44 of the Financial Market Supervision Act. The penalty is up to three years in custody or a monetary penalty, and negligent conduct carries a fine of up to CHF 250,000. Licensed and SRO-affiliated firms can also face supervisory action and reputational damage if their AML controls fall short.

Ready to Get Clarity on Your Risks?

From wallet screening and KYT monitoring to deep-dive investigations, Scorechain gives you everything you need to stay compliant, secure, and audit-ready.