Switzerland · Fintech Licence

Swiss Fintech Licence (Banking Act Art. 1b)

Article 1b of the Swiss Banking Act lets a FINMA-licensed company hold public deposits, or designated crypto-based assets, up to CHF 100 million - provided it neither invests the money nor pays interest on it. It is a genuine FINMA licence with a deliberately lighter perimeter, held by exactly five firms as of July 2026. It is not an EMI - Switzerland has no such category - and it carries no EU passport. For the narrow corridor of models it was written for, it is precisely the right instrument.

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CHF 100m: Cap on public deposits or designated crypto under Art. 1b Banking Act - no investing the float, no interest paid
CHF 300k: Minimum capital floor - 3% of deposits held, fully paid in; a full bank needs CHF 10m
5: Licence holders on FINMA's public register as of 10 July 2026 - a niche instrument, not a mass route
FINMA: Licenses and supervises Art. 1b firms directly - prudential-lite plus AML, no SRO membership involved

The route in short

Since 1 January 2019, the Banking Act's Art. 1b fintech licence has let firms mainly active in the financial sector hold public deposits - and, since August 2021, designated crypto-based assets - up to CHF 100 million, neither invested nor interest-bearing. FINMA issues the licence and supervises holders directly, under a regime deliberately lighter than banking: accounting under the Code of Obligations alone, no capital-adequacy or liquidity ordinances, minimum capital of 3% of deposits with a CHF 300,000 floor. Switzerland is outside the EU and EEA, so no passport rides on the licence - and no EU rulebook applies to it either. Where it sits among the Swiss routes is mapped on our Switzerland overview.

Read this first

Five licensees, no EMI category, no EU passport

Three facts come before any pitch. First, Switzerland has no EMI licence - and no "small EMI" or SEMI licence either. Those are EU categories; pages offering a "Swiss EMI" import vocabulary into a legal system that does not contain it. What actually exists for e-money-shaped models is the fintech sandbox, SRO affiliation for AML coverage and this Art. 1b licence - our guide to why Switzerland has no EMI licence does the translation properly.

Second, FINMA's register showed exactly five Art. 1b licence holders as of 10 July 2026 - seven and a half years into the regime. That is a strong credibility signal, and equally clear evidence of a niche instrument for a specific corridor of models, not a licence every fintech founder should want.

Third, nothing here passports. The border that keeps Switzerland outside MiCA, the E-Money Directive and PSD2 - and keeps this perimeter lighter - also means EU-facing distribution needs an EU-licensed entity or a state-by-state third-country analysis. The trade is symmetrical, and we will not pretend otherwise.

The fit

Who genuinely needs an Art. 1b licence

The corridor is precise: models that hold pooled client money, or payment-type crypto in collective custody, without lending it on. In practice - payment apps and wallets carrying customer balances, processors whose float outgrows the Banking Ordinance's settlement-account carve-outs, prepaid and stored-value products, marketplace float, collective custody of payment tokens. The statute bars the classic banking revenue line - no investing the float, no interest paid - so the business earns fees, not margin.

It is also the honest on-ramp to a bank: run under Art. 1b up to the CHF 100 million cap, and crossing it means ten days to notify FINMA and ninety days to file for a banking licence. At the other end, a proof of concept holding under CHF 1 million can live in the sandbox before any licence is needed - see what CHF 1 million really buys you.

Know the boundaries. There is no Swiss "crypto licence": exchange, brokerage and custody-as-intermediary models without deposit-taking sit in the AMLA tier, affiliated to one of the 11 FINMA-recognised SROs - the route on our Switzerland crypto page, with the SRO comparison as the chooser. Stablecoin issuance is generally deposit-taking under FINMA's Guidance 06/2024 - a banking-law question from day one. Portfolio managers are a different regime again: FinIA licensing, supervised by one of the four authorised supervisory organisations - SOs, not to be confused with SROs - on our portfolio manager route. And operating a deposit-taking model unlicensed is a criminal offence under Art. 44 FINMASA.

The ladder

From sandbox to full bank - where Art. 1b sits

Rung	Who supervises	What it permits	The hard edge
Rung Sandbox (Art. 6 Banking Ordinance)	Who supervises No prudential supervisor - that is the point; AMLA still applies to payment models	What it permits Up to CHF 1m in public deposits without a licence - investing allowed, interest-margin business barred, clients warned in text form of no supervision and no deposit insurance	The hard edge Breach the cap and it is ten days to notify FINMA, thirty to file; payment models still need SRO affiliation
Rung SRO affiliation (Art. 14 AMLA)	Who supervises One of the 11 FINMA-recognised SROs - AML supervision only	What it permits Para-banking as a financial intermediary - payments, exchange, custody-as-intermediary	The hard edge Never permits professional public deposit-taking - that always needs Art. 1b or a banking licence
Rung SO supervision (FinIA)	Who supervises One of the 4 authorised supervisory organisations, for FINMA-licensed portfolio managers and trustees	What it permits Asset management and trustee activity - a different population entirely	The hard edge Not a deposit-taking rung at all - and an SO is not an SRO
Rung Fintech licence (Art. 1b Banking Act)	Who supervises FINMA directly - prudential-lite plus AML	What it permits Public deposits and collectively custodied payment crypto up to CHF 100m, on fee-based revenue	The hard edge No investing, no interest, no deposit insurance; crossing CHF 100m forces a 90-day march to a full bank application
Rung Full bank (Art. 1a Banking Act)	Who supervises FINMA - full prudential and AML supervision	What it permits Deposit-taking with interest-margin business; depositor privilege up to CHF 100,000 per creditor	The hard edge CHF 10m minimum capital, fully paid, and the whole prudential rulebook

The file

What FINMA expects to see

A Swiss company, managed from Switzerland
An AG, GmbH or partnership limited by shares, with registered office and actual management in Switzerland and managing officers resident where they can genuinely run the business - a brass plate fails Arts. 14a and 14c of the Banking Ordinance.
Capital that scales with the float
Fully paid minimum capital of 3% of the public deposits and collectively custodied crypto held, floor CHF 300,000, maintained permanently - and FINMA may require more against the model's risks.
Governance and controls sized to the model
Where scale requires a separate board, at least three members with one-third independent of management; compliance and risk functions independent of revenue-generating units, with relief possible below CHF 1.5 million gross revenue where the model is demonstrably low-risk.
Fit-and-proper people - including the owners
Management must guarantee irreproachable business conduct; qualified participants holding 10% or more are vetted for reputation and influence. Foreign control triggers the additional licence under Art. 3ter of the Banking Act - directly relevant to non-Swiss acquirers.
Client money held the prescribed way
Deposits segregated or separately booked, parked as sight deposits with a bank or another Art. 1b firm or in category 1 high-quality liquid assets, currency-matched; crypto stays in Switzerland in the form received. Clients are warned in text form, before contracting, that there is no deposit insurance.
A file built to FINMA's own checklist
The application guidelines of 24 April 2025 expect a three-year business plan in three scenarios, a monthly year-one liquidity plan on the pessimistic case, AML policies, outsourcing contracts, custody and cap-monitoring design, and a written audit mandate - two audit tracks then run permanently.

The economics

Fees, costs and what SKY7 charges

Two fee layers exist, and only one has a published number. Ongoing supervision is charged under the FINMA Fees and Charges Ordinance (FINMA-GebV, SR 956.122, on fedlex.admin.ch, consolidation of 1 March 2024): a basic annual levy of CHF 3,000 per Art. 1b firm, plus an additional levy for the fintech supervisory area weighted two-tenths by balance-sheet total and eight-tenths by gross revenue.

The one-off licensing decision has no dedicated line in that ordinance's tariff annex; where no tariff is set, fees run on time spent at CHF 100-500 per hour. Which basis FINMA applies to fintech-licence decisions is not published - so we print no flat "licence fee" figure, and suggest treating flat figures elsewhere with caution. Adviser marketing circulates all-in ranges from roughly CHF 350,000-500,000 to CHF 1.1-2.4 million over 18 months; unofficial estimates, not FINMA figures.

SKY7's own fees are quoted on request once the scope is clear - how a mandate runs shows the shape of the engagement. Budget honestly for substance either way: resident executives, premises, segregated client money and two permanent audit tracks are real costs.

The reform

The licence is slated to be replaced - plan accordingly

As of July 2026, Art. 1b is the law in force - textually unchanged even in the pre-published 1 October 2026 consolidation of the Banking Act on fedlex.admin.ch. Its successor is drafted, though: on 22 October 2025 the Federal Council opened consultation on a Financial Institutions Act revision that would replace the fintech licence with payment instrument institutions - the CHF 100 million cap removed, client funds segregated in insolvency (closing today's no-protection gap), and a right to issue value-stable crypto-based payment instruments, framed in the Federal Council's own release as the counterpart of e-money tokens under EU law: a parallel Swiss regime, not access to the EU one. A crypto institutions category is proposed alongside. Consultation closed on 6 February 2026; the dispatch to Parliament was still pending as of July 2026.

The transition is the unknown: grandfathering terms for existing holders will only be known from the dispatch, and they are the single most important variable in any buy-versus-build decision - we will not guess them. Five companies hold this licence, no official source lists any for sale, and third-party "ready-made" offers are unverified trade claims; acquiring a holder means buying the licensed company, with reportable participant changes, FINMA's prior authorisation for material changes and the additional licence for foreign control. Where a model fits the AML tier instead, SKY7 holds live Swiss SRO-affiliated companies - see the crypto route above.

The mandate

How SKY7 runs an Art. 1b project

Fit check before anything else
A float earning margin means a banking conversation; balances under CHF 1 million may mean the sandbox first; exchange or custody without deposit-taking means the SRO tier; needing EU passporting means a different jurisdiction. We say so plainly.
Perimeter confirmed with FINMA
Where classification is genuinely uncertain, we prepare a pre-application meeting or an authorisation enquiry via FINMA's digital platform - median enquiry processing fell from 141 days in 2021 to 25 in 2024, a figure for enquiries, not licences.
The file, built to FINMA's checklist
Three-scenario business plan, monthly year-one liquidity plan, capital and its scaling, custody and cap-monitoring design, AML framework, fit-and-proper dossiers down to beneficial-owner level, audit mandate - per the guidelines of 24 April 2025.
FINMA assessment
No fixed statutory deadline exists; FINMA says duration depends on the project's complexity and the application's quality and completeness. We manage the information requests; we do not promise dates, because nobody honestly can.
Operate - and watch the reform
Ongoing supervision, both audit tracks, annual levies, prior authorisation for material changes - and a standing watch on the FinIA dispatch, because transition terms will shape every holder's options.

FAQ

Swiss fintech licence FAQ

01 Is the Swiss fintech licence an EMI or e-money licence?

No - Switzerland has no EMI or SEMI category. The fintech licence is a Banking Act instrument: public deposits up to CHF 100 million, no interest, no investment, no EU passport. The Swiss counterparts of an EU EMI are the sandbox, SRO affiliation or Art. 1b, model depending - and tomorrow, possibly, payment instrument institutions under the FinIA revision.

02 Does the licence give access to EU or EEA markets?

No. Switzerland is outside the EU and EEA, so there is no MiCA, e-money or payment-services passporting. That is symmetrical with the advantage - EU rulebooks do not apply either - but EU-facing business needs an EU-licensed entity or a country-by-country third-country analysis. If EU access is core, choose an EU route.

03 Is there a Swiss crypto licence I should apply for instead?

No such licence exists. Exchange, brokerage and custody models without deposit-taking are AML-supervised through one of the 11 FINMA-recognised SROs; prudential licences trigger only for specific activities; Art. 1b itself covers collectively custodied payment-type crypto. A "crypto institutions" category is a proposal in the FinIA revision - not law as of July 2026.

04 How much capital does an Art. 1b licence require?

3% of the public deposits and collectively custodied crypto held, floor CHF 300,000, fully paid and maintained permanently - FINMA may require more against the risks. The capital-adequacy and liquidity ordinances do not apply; a full bank, by contrast, needs CHF 10 million.

05 What are the government fees for the licence?

Supervision costs a basic levy of CHF 3,000 per year plus an additional levy weighted by balance-sheet total and gross revenue (FINMA-GebV). The licensing decision has no dedicated tariff line - where none exists, fees run on time at CHF 100-500 per hour, and FINMA does not publish which basis it applies. Verify the ordinance on fedlex.admin.ch before budgeting.

06 How long does FINMA take to grant the licence?

There is no statutory deadline and we do not promise timelines. FINMA says duration depends on the project's complexity and the application's quality and completeness, and offers pre-application meetings. Adviser estimates of six to twelve months or more circulate - colour, not FINMA figures.

07 Can I buy a ready-made Swiss fintech licence?

There is no shelf market: five companies hold the licence and no official source lists any for sale. An acquisition means buying the licensed company under FINMA's eyes - reportable participant changes, prior authorisation for material changes, an additional licence for foreign control - plus transition risk that is unpriceable until the reform's grandfathering terms are published.

Go deeper

Guides for this route

The Swiss fintech sandbox - what CHF 1 million buys

The 20-deposit rule, the CHF 1m cap, breach mechanics - and the AMLA trap most guides miss.

Switzerland has no EMI licence

Translating EU e-money vocabulary into the Swiss instruments that actually exist.

Switzerland route overview

Every Swiss route - SRO affiliation, the fintech licence, portfolio managers - and how the tiers fit.

Reviewed by the SKY7 advisory team. Last reviewed: 11 July 2026. Regulatory facts on this page are stated as of July 2026, from the Banking Act (SR 952.0), the Banking Ordinance (SR 952.02), the FINMA Fees and Charges Ordinance (SR 956.122) and FINMA's published pages and registers. This page is general information only, not legal, regulatory, tax, investment or financial advice. The Art. 1b regime is in active reform - the Federal Council's proposal of 22 October 2025 would replace the fintech licence with a payment instrument institutions category - and the licensee register, fee schedule and legislative status all move: verify the current position on finma.ch, fedlex.admin.ch and sif.admin.ch before relying on anything here.

Tell us what you need

Test the corridor before you commit

Tell us what you hold, for whom, and where your customers sit. SKY7 will tell you honestly whether Art. 1b is your rung - or whether the sandbox, an SRO affiliation or a full banking application serves you better - and run the mandate end to end if it is.