When Switzerland launched the fintech licence in 2019, the idea was elegant: a “banking licence light” for innovative firms that wanted to hold client money without carrying the full weight of a bank. Seven years later, six institutions hold one, according to FINMA’s own register, and two earlier holders ended in bankruptcy. Bern has drawn its own conclusion and is replacing it.
A licence nobody wanted
In its December 2022 evaluation, the Federal Council admitted that the fintech licence had achieved only limited market success. That is official language for a flop. Its own count: “Since 2019 and until mid-2022, four institutions obtained the 1b licence, whereby FINMA opened bankruptcy proceedings against one.”
The design explains why. A fintech licence holder may accept public deposits up to CHF 100 million, but may not pay interest on them and may not invest or lend them. The business earns fees, not margin. In practice, it is a bank with the profit engine removed.
Clients had little reason to prefer it either. If a fintech institution goes bankrupt, client funds are neither privileged nor covered by deposit insurance. They are ordinary claims in the bankruptcy. Add the fact that a Swiss licence gives no access to the EU market, and most founders made the rational choice. They ran their payment business under SRO membership, with a licensed partner holding client money, or they went to Lithuania or Ireland. How that SRO route works for crypto businesses is explained in our Swiss Crypto Licence 2026 guide.
When the weakness became real
In 2022, FINMA opened bankruptcy proceedings against a fintech licence holder for the first time: Mogli AG, licensed only in April 2021. The cause was never made public.
In March 2025 it happened again, this time in Geneva. FINMA withdrew the licence of Swiss4.0 and opened bankruptcy proceedings over justified concerns that the firm was over-indebted and had serious liquidity problems. It was a micro start-up with around 250 clients. Those 250 clients became ordinary creditors.
FINMA’s own comment was remarkably candid. Low entry requirements, it said, also mean a higher probability that a business model turns out not to work. That is a fair point, but the clients are the ones who pay for it.
What comes next: two new licences
The Federal Council has proposed amendments to the Financial Institutions Act (FinIA). The consultation closed in February 2026. Parliament still has to adopt the law, and 2027 or 2028 is the realistic horizon.
1. The payment instrument institution
This is the successor to the fintech licence, and it fixes its main flaws:
- The CHF 100 million cap disappears.
- Client funds must be segregated and stay out of the bankruptcy estate. Swiss4.0’s clients would have had their funds segregated under this rule.
- It becomes the route for issuing Swiss stablecoins. Coins must be fully backed, held separately, redeemable at par, and announced by a white paper published at least 60 days before issuance.
- What does not change: still no interest on client funds and no lending of them. A payment institution is still not a bank.
2. The crypto institution
This is a new prudential licence for crypto-asset service providers:
- It covers custody (including staking), trading for clients, short-term proprietary trading and exchange services in payment and investment tokens.
- Utility tokens, financial instruments and bank deposits fall outside its scope.
- Activities that run today on SRO membership alone, above all custody and trading, are expected to move under direct FINMA supervision, with a transition period.
- The rules are modelled on the securities firm regime, but lighter and proportionate to crypto risks.
What this means for you today
The current fintech licence remains available until the new law is in force, and existing holders are expected to move into the payment institution category.
For crypto businesses currently operating on SRO membership, the message is simple: the comfortable status quo has an expiry date. The firms that plan their structure now, including capital, governance, client asset segregation and the audit set-up, will be licensed first when the new regime opens. The rest will still be reading the law. If you are starting now, the SRO remains the fastest way in — see our Swiss SRO Licence 2026 guide.
The Swiss4.0 case is a useful reminder that a licence is not a business model. Regulators can lower the entry barrier. They cannot make your revenue appear.
For a detailed look at both new licences, read our earlier article: Two New Swiss Fintech Licences: Get Ready First.
Questions about your structure under the new regime: insight@fintechlex.com
This article is for general information only and does not constitute legal advice.
