Zurich from the air
Home › Licensing › Switzerland › Switzerland fintech licence
Licence guide

Switzerland fintech licence.

Payment, wallet and crypto businesses that hold customer balances in Switzerland without lending them use this licence, the step between the sandbox and a full banking licence.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
FINMARegulator
CHF 300,000Minimum capital
CHF 100 millionDeposit cap
Charged by the hourLicensing fee
6 to 8 monthsOur realistic timeline

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 8 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for managers in Switzerland and independent directors, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. Whether the business needs the fintech licence or SRO affiliation, its deposit position against the exemptions and the capital are confirmed in writing, together with the three-scenario budget FINMA expects.
  2. Application pack. The business plan, three-year budget and monthly liquidity plan, the organisation chart, the risk, compliance and ICT documentation and the manager and major shareholder files with extracts under three months old for FINMA.
  3. Banking. The sight deposit account for client deposits, which is a licence condition, and the operating accounts are arranged through the firm’s relationships with banks serving regulated fintechs before the decision.
  4. Regulator engagement. FINMA questions are answered through one process with the evidence assembled, including any licensing audit report FINMA orders, until the decision; operations start only once the licence is granted.

Key people, banking and technology

You will need managers living close enough to run the business from Switzerland, and a board of at least three, one third independent of management.

Key peopleThe firm introduces candidates for managers in Switzerland and independent directors from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • The fintech licence under Article 1b of the Banking Act allows a company mainly active in finance to accept public deposits of up to CHF 100 million, or crypto-based assets, provided it neither invests them nor pays interest.
  • Capital is 3% of the deposits accepted and at least CHF 300,000, fully paid in and maintained at all times.
  • FINMA charges licensing by time at CHF 100 to CHF 500 per hour; the annual levy is a CHF 3,000 base plus a variable element by balance sheet and gross income.
  • There is no statutory decision period; FINMA has received about 30 applications since 2019 and had licensed 7 companies by the end of 2025.
  • The company is an AG, Kommandit-AG or GmbH with its seat and actual management in Switzerland; the licence carries no EU passport.
  • Payment services without deposit-taking need affiliation to a FINMA-recognised self-regulatory organisation under the Anti-Money Laundering Act rather than a FINMA licence.

Who needs the licence

A company that holds customer balances in Switzerland, such as a payment account, wallet or prepaid provider, accepts public deposits and needs a licence once the balances exceed the Banking Ordinance exemptions: settlement balances cleared within 60 days, small prepaid balances for future purchases of up to CHF 3,000 per person, and the CHF 1 million sandbox. The fintech licence covers deposits up to CHF 100 million without lending or interest; above that, or where deposits are invested or interest is paid, a banking licence applies. A payment business that moves money without holding deposits joins a self-regulatory organisation instead.

The three tiers

TierDepositsConditions
Sandbox (Banking Ordinance, Article 6)Up to CHF 1 millionNo interest-differential business; written warning to depositors that FINMA does not supervise and no deposit insurance applies; on exceeding, report to FINMA within 10 days and apply within 30 days
Fintech licence (Banking Act, Article 1b)Up to CHF 100 millionNo investment of deposits and no interest; FINMA licence and supervision
Banking licence (Banking Act, Article 3)Above CHF 100 millionOr where deposits are invested or interest paid

What FINMA requires

  • Legal form and location. An AG, Kommandit-AG or GmbH with its seat and actual management in Switzerland; effective management from Switzerland, with managers resident where they can run the business.
  • Governance. A precise business scope and a suitable management organisation; where a governing body is required, at least three members with at least one third independent of management; shareholders of 10% or more of good repute; risk management, internal control and compliance functions independent of revenue-generating units and documented in writing, with relief available below CHF 1.5 million of gross income for a low-risk model.
  • Capital and financial planning. Minimum capital of 3% of public deposits and at least CHF 300,000, fully paid in and not lent to major shareholders or related persons; a three-year budget under optimistic, realistic and pessimistic scenarios, a monthly year-one liquidity plan under the pessimistic case, and a demonstration of how the capital keeps pace as deposits grow.
  • Custody of deposits. Deposits and custodied crypto-assets held separately from own funds, or recorded so they can be shown separately at any time; deposits held as sight deposits at a bank or as Category 1 high-quality liquid assets; crypto-assets held in Switzerland in the form received. There is no deposit insurance and no privileged-deposit treatment, and clients are told so in writing before depositing.
  • Audit and changes. Accounts under the Code of Obligations, audited annually, with a regulatory audit by an audit firm approved by the Federal Audit Oversight Authority; prior FINMA approval for changes to key documents, major shareholders (10% or more), management, organisation, activities, outsourcing of core services and foreign activities.
  • Application pack. In an official language or English, with the articles and regulations in an official language: commercial register and debt extracts, group chart, business plan and budget, liquidity plan, organisation chart with full-time equivalents, risk, compliance and ICT documentation, outsourcing contracts, any crypto custody description and the audit firm’s acceptance; for each manager and major shareholder, identity documents, a residence permit for foreign nationals, criminal and debt-collection extracts under three months old, a signed CV with two references and the FINMA forms. FINMA may order a licensing audit report at the applicant’s cost. Operations start only once the licence is granted.

Capital

RequirementAmount
Minimum capital3% of public deposits accepted; at least CHF 300,000
FormFully paid in and maintained permanently; not lent to major shareholders or related persons
GrowthShown to keep pace with deposits under the three-year budget

FINMA’s guidelines require the budget under optimistic, realistic and pessimistic scenarios and a monthly liquidity plan for the first year under the pessimistic case.

Timing

FigureValueSource
Statutory decision periodNo statutory period; FINMA states that processing time depends on the project’s complexity and the quality and completeness of the applicationFINMA, fintech licence
Regulator’s published figurePreliminary enquiries answered in under 30 days on average, about 1 month; about 30 applications received since 2019 and 7 companies licensed by the end of 2025FINMA annual report 2025
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Licensing feeCHF 100 to CHF 500 per hourCharged by time according to staff level and the importance of the matter; no flat fee for Article 1b persons
Annual base levyCHF 3,000Per Article 1b person
Annual variable levyBy balance sheet and incomeTwo tenths by balance sheet total and eight tenths by gross income
Licensing audit reportAt costWhere FINMA orders one from an approved audit firm
Minimum capitalCHF 300,000Or 3% of deposits if higher
Professional feesFixed, in writingQuoted after scoping

The SRO route for payment services

A payment business that transmits money or value, issues means of payment such as cards or prepaid e-money, or operates a payment system, without holding public deposits beyond the Banking Ordinance exemptions, is a financial intermediary under Article 2 of the Anti-Money Laundering Act. It joins a FINMA-recognised self-regulatory organisation (SRO), which supervises it for anti-money laundering purposes; FINMA itself issues no licence. The activity is professional above CHF 50,000 of gross revenue a year, more than 20 contracting parties, assets under control above CHF 5 million or transaction volume above CHF 2 million a year, and money or value transfer is professional whatever its scale.

VQF itemAmount
Application administration feeCHF 2,000
Legal and compliance reviewCHF 300 to CHF 6,000 by effort
Annual membership feeCHF 400
Annual AML file feeCHF 30, 20 or 10 per file by band, or a turnover-based fee of CHF 500 to CHF 10,000
Minimum annual feeCHF 1,250
AdviceCHF 300 per hour

Figures are from the VQF fee regulations in force from 1 January 2026, excluding VAT. Admission runs from submission of documents and payment, through a completeness check and a legal and compliance review, to an admission interview and written confirmation. SRO affiliation does not permit holding public deposits: settlement balances cleared within 60 days, small prepaid balances and the CHF 1 million sandbox are the limits, and beyond them the fintech or banking licence applies.

Geographic scope

The licence covers Switzerland only and carries no EU or EEA passport. The business is conducted in Switzerland; cross-border activity is a change requiring FINMA’s approval and documentation of the cross-border risk. Groups serving the EU hold a separate EU authorisation, which the firm obtains alongside.

Why applications are delayed

FINMA states that processing time depends on the complexity of the project and on the quality and completeness of the application, and reports that a relatively large share of applications did not qualify for a licence: about 30 applications since 2019 and 7 licences by the end of 2025, with 4 of those companies still operating. The firm plans around FINMA’s own requirements.

  1. The project. A precise business scope, a budget under three scenarios and a liquidity plan, and a demonstration that capital keeps pace with deposits.
  2. The organisation. Risk, compliance and internal control independent of the revenue side, documented, and managers resident where they can run the business.
  3. Good repute. Complete files on every manager and major shareholder, with extracts under three months old.

FINMA notes in its 2025 report a planned payment instrument institution licence intended to replace Article 1b; the firm tracks the proposal and advises on timing.

Banking

A fintech licensee holds client deposits as sight deposits at a bank or in Category 1 high-quality liquid assets, so a Swiss bank relationship is a licence condition rather than an afterthought. The firm arranges the deposit account and the operating accounts through institutions that serve regulated fintechs in Switzerland, during the application, so the company trades on licensing. See banking and payment processing.

Questions firms ask

How long does a FINMA fintech licence take?

There is no statutory period; FINMA states the time depends on the project’s complexity and the quality and completeness of the application, and answers preliminary enquiries in under 30 days on average. The firm plans for six to eight months after submission.

What capital does the fintech licence need?

3% of the public deposits accepted and at least CHF 300,000, fully paid in, maintained permanently and not lent to major shareholders or related persons.

What does FINMA charge?

Licensing by time at CHF 100 to CHF 500 per hour, then an annual base levy of CHF 3,000 plus a variable levy by balance sheet total and gross income.

Does a payment company need the fintech licence?

Only where it holds public deposits beyond the exemptions: settlement balances within 60 days, prepaid balances up to CHF 3,000 per person and the CHF 1 million sandbox. Money transmission, card issuing and payment systems without deposits need SRO affiliation under the Anti-Money Laundering Act.

Does the licence cover the EU?

No. It covers Switzerland only, and cross-border activity needs FINMA’s approval as a change. Groups serving the EU hold an EU authorisation alongside it.

References

  1. FINMA: fintech licence
  2. FINMA: guidelines for fintech licence applications, 24 April 2025
  3. Banking Act (SR 952.0), Article 1b
  4. Banking Ordinance (SR 952.02), Articles 6, 7a, 14a to 14g and 17a
  5. FINMA Fees and Levies Ordinance (SR 956.122), Articles 8, 19e and 19f
  6. FINMA annual report 2025

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.