There is no single “Swiss crypto licence”. There is a map: what you can run on an SRO today, what needs a partner or a FINMA licence, and what the 2027 reform will change.
The short answer
- Most crypto businesses start on an SRO. Exchange, brokerage, OTC, custodial and non-custodial wallets, segregated custody, staking and crypto-backed lending from your own funds can all run on SRO affiliation under the Anti-Money Laundering Act.
- An SRO is not enough to hold client fiat as deposits, issue a stablecoin, run an exchange for security tokens, manage a crypto fund or manage portfolios on a discretionary basis.
- Fiat is the bottleneck, not crypto. Client money runs through a partner bank or electronic-money institution until you hold your own licence.
- The rules are changing. A new FINMA crypto-institution licence is coming. The SRO is the place to start, not to stay forever.
First, there is no single “crypto licence”
Switzerland has no all-purpose crypto licence. It regulates what you do, not the technology you use. The same rules apply whether the asset is a franc or a token: who holds the client’s money or assets, whether that is a deposit, and whether you are selling a regulated product.
In practice, a crypto business in Switzerland sits on one or more of five layers:
| Layer | What it is | Typical use for crypto |
| SRO affiliation | Anti-money laundering supervision by a self-regulatory organisation recognised by FINMA | Exchange, brokerage, wallets, custody, staking, crypto-backed lending |
| White-label partner | A licensed bank or electronic-money institution that holds client fiat for you | IBANs, fiat accounts, cards, fiat on- and off-ramp |
| FINMA licence | Bank, fintech licence, securities firm, DLT trading facility, portfolio manager, fund | Deposits, stablecoin issuance, token exchanges, crypto funds |
| Product regimes | Collective investment schemes, insurance, consumer credit | Yield funds, insurance cover, consumer loans |
| 2027 reform | New crypto-institution and payment-institution licences | Custody and trading under direct FINMA supervision |
How a token is classified also matters. FINMA distinguishes payment tokens, utility tokens and asset tokens, and an asset token that qualifies as a security brings securities rules with it. I explained that in Token Classification: The Key to Swiss Crypto Regulations.
What you can run on an SRO today
A company that accepts, holds or transfers crypto-assets for clients on a professional basis is a financial intermediary under the Anti-Money Laundering Act. It must join an SRO, which supervises its anti-money laundering compliance. On that basis, the following activities can run without a FINMA licence:
| Activity | On an SRO today? | Condition |
| Crypto exchange — buy, sell, swap against your own book or a liquidity provider | Yes | No client fiat held as deposits |
| Brokerage and OTC desk | Yes | Bilateral execution, full KYC and transaction monitoring |
| Non-custodial (self-hosted) wallets | Yes | Often outside the AML perimeter altogether, depending on the model |
| Custodial wallets and cold-vault custody | Yes | Crypto segregated and allocated per client — see below |
| Staking | Yes | Client assets stay segregated; staking terms disclosed |
| Crypto-backed and staking-backed loans | Yes | Lent from your own or shareholder funds; consumer loans bring the Consumer Credit Act into play |
| Crypto and fiat payment solutions for merchants | Yes, for the AML layer | Merchant settlement through a licensed acquirer |
| Prepaid spending wallet | Yes, within limits | Up to CHF 3,000 per client, payment-only, no interest, no cash-out |
This is how most Swiss crypto businesses started, including some of the largest. The SRO route is fast, proportionate and recognised by banks and counterparties. How to obtain it — routes, requirements, timeline and cost — is set out in our Swiss SRO Licence 2026 guide.
Where the SRO stops
The single principle behind every answer: SRO affiliation is anti-money laundering supervision, nothing more. It lets you act as a financial intermediary. It does not authorise you to take deposits, run an investment product or underwrite risk.
| You want to… | On your SRO alone? | Route today |
| Hold client fiat in accounts | No — that is taking deposits | Partner bank or EMI on a white-label basis; or a fintech licence |
| Issue IBANs and cards | Not directly | White-label bank or EMI; card programme with a licensed issuer |
| Issue a stablecoin redeemable in francs, euros or dollars | No | Banking or fintech licence, or the bank default-guarantee model (FINMA Guidance 06/2024) |
| Run an exchange that lists security tokens | No | DLT trading facility, securities firm or exchange licence |
| Offer crypto “yield” funds | No | Collective investment schemes regime — or distribute an authorised third-party fund |
| Manage client portfolios on a discretionary basis | No | FINMA portfolio-manager licence plus a supervisory organisation |
| Insure client holdings through your own captive | No | Insurance licence — or distribute third-party cover |
A “no” in this table rarely means “not at all”. It means “not on your own SRO”. Almost everything can still be offered through a licensed partner, or housed in a separate entity with the right licence.
Custody: segregation is everything
Crypto custody is where the line between an SRO business and a bank is thinnest. Since the DLT Act, crypto-assets held for clients can be separated from the custodian’s estate in bankruptcy (Debt Enforcement and Bankruptcy Act, art. 242a), provided they are held for the client and allocated to him at all times.
- Segregated, allocated per client: not a deposit. It can run on an SRO today.
- Pooled, not allocated, or used by the custodian: it turns back into a deposit, and into banking territory.
- Using a sub-custodian: choose a supervised one and document the segregation. FINMA’s 2026 guidance on crypto custody (Guidance 01/2026) sets out its expectations on key governance, segregation and foreign sub-custodians.
Multi-signature wallets, hardware security modules and documented key ceremonies are no longer a technical detail. They are what the SRO, the auditor and the bank will ask to see.
Stablecoins and tokens
Issuing a stablecoin
A stablecoin that holders can redeem at par in francs, euros or dollars gives them a claim on the issuer. Under Swiss banking law, that claim is treated like a deposit. Today, the routes are a banking licence, a fintech licence, or a bank default guarantee covering every holder’s claim — a model FINMA tightened in its Guidance 06/2024. I described one structure in Swiss Issuing Stablecoin with a SRO. Under the reform, issuing a Swiss single-currency stablecoin becomes the exclusive preserve of the new payment-institution licence.
Issuing and trading asset tokens
An SRO-supervised company can issue tokenised shares, bonds or claims and place them with its clients, provided it respects the prospectus and financial services rules. What it cannot do is run a platform that brings together many buyers and sellers of security tokens under non-discretionary rules. That is a trading venue, and it needs a FINMA licence (DLT trading facility, securities firm or exchange).
Since the DLT Act came into force on 1 February 2021, Swiss law recognises ledger-based securities, which makes tokenised shares and bonds legally sound — see Swiss Legal Framework for Asset Tokenization. For token-generation projects, the issuing entity is often a Swiss foundation: Swiss Foundation’s Role in Initial Coin Offerings.
There is a practical middle way for an SRO company: a closed-loop client board, open only to fully onboarded clients, where they post non-binding expressions of interest. No order book, no automatic matching, no price-time priority. Matching interests are executed bilaterally, off-platform, with the intermediary handling documentation, anti-money laundering checks and settlement. Designed carefully, it gives token holders an exit without becoming an exchange.
Crypto lending and staking
Lending from your own capital is not a licensed activity in Switzerland. A crypto business on an SRO can lend fiat or stablecoins against crypto collateral, and even hold staked assets as collateral, provided two lines hold:
- The money lent is your own — equity, shareholder loans or funds from qualifying participants — never client balances or re-used collateral. Funding loans with clients’ money is taking deposits.
- Lending to consumers brings the Consumer Credit Act into play. Kept business-to-business, the model stays inside the SRO envelope.
Combined with an exchange, lending becomes a strong model: one KYC for both, collateral liquidated on your own platform, and revenue from interest, trading spreads and staking. I set out the full architecture in Swiss Integrated Fiat Crypto Lending and Exchange Model.
The real bottleneck: fiat and banks
The SRO admits you. The bank decides whether you can operate. Many crypto projects obtain their affiliation and then wait months for an account that will accept client flows. Without fiat, a crypto exchange is dead on arrival.
The structures that work separate the layers:
- Corporate and treasury: an account with a crypto-friendly Swiss bank.
- High-net-worth and OTC clients: a private bank able to handle large crypto-fiat transactions.
- Retail clients: accounts, IBANs and cards through a licensed electronic-money institution on a white-label basis.
This is also why existing crypto companies that already hold an SRO membership and working bank relationships trade at a premium. You are buying time and access, not a certificate.
What changes from 2027
On 22 October 2025 the Federal Council opened a consultation, closed on 6 February 2026, on two new licences under the Financial Institutions Act:
- Crypto-institution — for custody, trading, dealing for clients and market making in crypto-assets. Activities that run on an SRO today, above all custody and trading, are expected to move under direct FINMA supervision, with a transition period. The licence also gives staking and foreign sub-custody a statutory basis.
- Payment-institution — the successor to the fintech licence: no CHF 100 million cap, client funds protected in bankruptcy, and the only route to issuing a regulated Swiss stablecoin.
Some crypto activities are expected to stay on the SRO: non-custodial wallets, own-account dealing without market making, and dealing in Swiss stablecoins. The SROs have also raised their minimum standards for crypto service providers in 2026, so the SRO route itself is getting more demanding.
No date of entry into force has been set. The sensible course in 2026 is to start on an SRO, build a track record and bank relationships, and prepare the licence file in parallel. How to get ready is explained in Swiss Two New Fintech Licenses: Get Ready First.
Switzerland or MiCA?
Switzerland is not in the EU, so a Swiss crypto company has no MiCA passport into the European market. For a business serving EU retail clients at scale, a MiCA CASP licence may be the better primary licence; for international, high-net-worth and B2B clients, Switzerland’s proportionate SRO route and its banking ecosystem remain hard to beat. Many groups end up with both. For EU firms that missed the 1 July 2026 deadline, see MiCA After 1 July 2026: What Crypto Firms Without a CASP Licence Can Still Do.
Cost and timeline
The crypto route uses the same three paths as any SRO company:
- Build from scratch: about 4–5 months, from about CHF 89,000 in fees plus share capital.
- Shell company plus application: about 10–12 weeks, about CHF 129,000 all-in.
- Ready-made crypto company, already admitted to an SRO and banked: about 2–3 weeks. Prices depend on availability and market conditions — contact us at insight@fintechlex.com.
Add the crypto-specific layers to your budget: exchange or custody software, liquidity providers, wallet infrastructure and, for retail, the white-label IBAN and card programme. Details in our Swiss SRO Licence 2026 guide.
Frequently asked questions
Is there a crypto licence in Switzerland?
Not a single one. Most crypto businesses operate on SRO affiliation under the Anti-Money Laundering Act. Deposits, stablecoin issuance, token exchanges and crypto funds need a FINMA licence. A dedicated FINMA crypto-institution licence is planned under the reform consulted on in 2025–2026.
Can I run a crypto exchange in Switzerland with an SRO?
Yes, for buying, selling and swapping crypto-assets, provided you do not hold client fiat as deposits. Fiat runs through a partner bank or electronic-money institution. An exchange for security tokens needs a FINMA licence.
Do I need FINMA approval for crypto custody?
Not today, if client crypto-assets are segregated and allocated to each client. Pooled custody can amount to taking deposits. Under the reform, custody is expected to move under the new crypto-institution licence.
Can a Swiss SRO company issue a stablecoin?
Not on SRO affiliation alone. Today it needs a banking or fintech licence, or a bank default guarantee covering all holders. Under the reform, Swiss single-currency stablecoins will be issued by payment institutions.
How long does it take and what does it cost?
About 4–5 months and from about CHF 89,000 plus share capital from scratch; about 10–12 weeks and CHF 129,000 with a shell company. A ready-made crypto company is faster; price on request.
Is a Swiss crypto company valid in the EU?
No. Switzerland has no MiCA passport. Serving EU clients at scale requires a MiCA CASP licence or an EU partner.
Planning a Swiss crypto business?
Tell us what you want to offer — exchange, custody, lending, payments, tokens — and to whom. We will map each activity to the right route: SRO, partner, or licence, today and after the reform. Contact insight@fintechlex.com.
René-Philippe — FintechLex SA, Geneva | Hong Kong | London
General information, not legal advice. Classifications depend on the final legal and fund-flow structure. The crypto-institution and payment-institution licences are still at the draft stage; the position described is that of October 2026.
