By Rene Philippe Raymond Dubout · · Updated Dear reader,
For years, a Swiss FinTech licence was a rare animal. Few companies held one, and those who did could ask a good price when they wanted to sell. That is about to change. The reform of the Financial Institutions Act replaces it with a new licence, the payment instrument institution, and gives that licence something the old one never had: the exclusive right to issue Swiss stablecoins. A licence that opens a new market attracts applicants, and a rare animal stops being rare once everybody wants one. If you hold a FinTech licence, or plan to buy one, its value is about to be repriced.
So, as promised, this week is about stablecoins: the rules today and the new licence, why even a bank will need a separate company to issue one, why most fintechs should distribute rather than issue, why a Swiss franc coin is a hard business at zero interest, what happens at the EU border, where Tether’s money actually sits, why a stablecoin payment still takes some twenty steps inside a bank, and whether launching your own coin in 2026 still makes sense. The bill is not yet before Parliament, so read this as what is coming, not what is in force.
New this week
The story behind the SRO book, then five posts from our former blog, rewritten from scratch on the 2026 rules.
Swiss SRO in 2026: The Book I Thought Somebody Had Already Written
Why the SRO book should have been the first of the series, why it took six, and why “the cheapest and fastest way to run a regulated business in Switzerland” is only half true.
Puerto Rico IFE Licence in 2026: USD 10 Million Capital, and Who It Still Makes Sense For
The 2024 reform raised the capital for a new IFE from USD 250,000 to USD 10 million, paid in full. Who it still suits, and the cheaper doors for everyone else.
Comoros Fake Regulators, Gambia Fake Offshore Licences
Neither country has real offshore banks. The Central Bank of The Gambia confirmed to us in writing in 2017 that it had licensed none. Read this before you buy any offshore licence.
Who can apply, what membership involves, and the rule of thumb: start sponsored, apply for principal membership once the sponsor’s share hurts.
The EMD Agent Route: How to Sell Payment Accounts Under Your Brand Without Your Own Licence
The fastest and cheapest way into regulated payments, the UK versus EU question since Brexit, and the one thing an agent can never do: issue e-money.
Geneva or Zug for Your Fintech? Tax, Banks, Talent and the Crypto Valley Legend
Same law, same FINMA. What changes is the tax bill, the language, the people you can hire and the bankers you will meet.
Stay up to date: get our free app. All our analysis and the regulated companies we have for sale, in one place on your phone. No account, no download: open fintechlex.com/app and add it to your home screen.
Stablecoins: the Swiss licence and the business behind it
From the new law to the business plan, in the order the questions arrive.
Issuing a Stablecoin in Switzerland: The Rules Today, and the Licence Coming Next
Switzerland has no stablecoin law yet, but FINMA applies its banking, fund and anti-money laundering rules (Guidance 06/2024). Deposit or fund, the bank-guarantee route, and why every holder must be identified, not just the first.
Stablecoin Licence Switzerland: What the New Payment Instrument Institution Will Allow
Switzerland is creating its first licence to issue stablecoins. What a Swiss stablecoin is, who may issue one, the reserve and redemption rules, and where the bill stands today.
Stablecoins: When Even a Bank Needs a Separately Licensed Subsidiary
Under the draft, a bank’s own licence will not cover issuing a stablecoin: it needs a separate group company with its own licence. Some call it red tape. I call it common sense.
Issuer or Distributor? Why Most Fintechs Should Not Issue Their Own Stablecoin
Issuers earn mainly interest on their reserves; distributors earn fees from the clients who use the coin. Why, for most fintechs, distributing beats issuing.
Why a Swiss Franc Stablecoin Is a Hard Business: The Zero-Rate Problem
With the SNB rate at zero, the reserves earn close to nothing while the costs stay. Where a franc stablecoin can still make money: fees, volume and shared infrastructure.
Stablecoins Across the Swiss–EU Border: USDT and USDC Coming In, Swiss Coins Going Out
MiCA is pushing USDT off EU platforms while USDC stays. Switzerland still allows USDT, but a Swiss franc coin has no passport into the EU.
Your Stablecoin Is Global. Its Reserves Are Not: The USDT Case
USDT circulates everywhere, but its reserves sit mainly in US Treasury bills with a New York custodian. What that means for you as a holder, and why direct redemption starts at USD 100,000.
Stablecoin Payments: Faster, Yes. Simpler, Not Really.
Stablecoins move money in minutes, but inside a bank the blockchain replaces one step out of about twenty. What that means if you are a bank or a fintech.
EMI, MiCA and Stablecoin Licences in Europe: Three Regimes, and What PSD3 Changes
Payments and e-money, crypto services, stablecoins: three rulebooks, and one company can hold several. Under the PSD3 text agreed in April 2026, the EMI licence would fold into a single payment institution licence.
Is There Still a Point in Launching a Stablecoin in 2026?
Use, distribute, brand or issue: four ways into the market, the reserve-income arithmetic nobody does, and the question that should sit at the centre of your business plan.
All of it in one place: Stablecoins in Switzerland and the EU: The Complete FintechLex Guide
Two books for those who hold crypto, rather than issue it
What Nobody Tells You Before You Invest in Crypto
Crypto · Investing · Risk
Crypto is easy to buy and hard to exit with your money intact.
A plain-language guide to the crashes, scams, tax traps, custody risks and inheritance questions that ordinary investors face.
Amazon · Apple Books · Google Play
What Nobody Tells You About the Plumbing of Crypto
Blockchains · Stablecoins · Banks · Payments
Your crypto wallet says you’re rich. Wonderful. Now try spending the money when the network stops working.
Your coins can be perfectly safe and still be unusable. This is the plumbing behind crypto — miners, validators, stablecoin issuers, banks, bridges and oracles — and what happens to your 20,000 euros when one of those parts stops working.
Amazon · Apple Books · Google Play
On the market
For Sale: A Ready-to-Launch International Bank in Dominica, with a Virtual Asset Registration
Two authorisations, USD 1 million of regulatory capital, a team on the ground, and no clients yet: no past to explain to a correspondent bank. Price on request, details to qualified buyers under NDA.
Next Tuesday
Offshore banks: build one, buy one, or walk away. What a licence really costs once you add the bank that goes with it.
Write to us
Thinking about a stablecoin, holding a FinTech licence, or weighing a licence purchase before the rules change? Write to insight@fintechlex.com. WhatsApp: +41 787 983 770.
Rene-Philippe
FintechLex SA · Geneva | Hong Kong | London · fintechlex.com
This newsletter is for general information only and does not constitute legal advice or an offer to sell any shares or securities. The payment instrument institution licence is at the consultation-draft stage and the bill is not yet before Parliament; the position described is that of October 2026.
