For years, launching a Swiss fund meant waiting for FINMA to approve it. Many managers simply went to Luxembourg instead. Since 1 March 2024 there is a Swiss answer: the Limited Qualified Investor Fund, or L-QIF, a fund that needs no FINMA authorisation and no FINMA approval.
“No approval” does not mean “no rules”. This guide explains what the L-QIF is, who may use it, and where the responsibility now sits. It is part of our guide to doing financial business in Switzerland.
What changes, and what does not
| Point | Traditional Swiss fund | L-QIF |
|---|---|---|
| FINMA approval | Required | Not required |
| FINMA supervision of the fund | Yes | No |
| Investors | Depends on the fund type | Qualified investors only |
| Who is responsible | Manager, under FINMA supervision | The FINMA-supervised manager alone |
The fund itself escapes FINMA. The manager does not: an L-QIF must be managed by specific institutions that are themselves supervised by FINMA, and they carry sole responsibility for complying with the L-QIF rules.
The legal forms
- Contractual fund: a fund contract between investors, fund management company and custodian bank.
- SICAV: an investment company with variable capital.
- Limited partnership for collective investment: the classic form for private equity and other long-term investments.
Which FINMA-supervised institution must manage the fund depends on the legal form chosen. Settle this first: it decides whether you can launch with the licence you already have, or need a partner. See Managing Funds in Switzerland.
Who may invest
Qualified investors only: professional and institutional investors, and, under the Collective Investment Schemes Act, private clients who have a portfolio management or long-term advisory relationship with a supervised institution, unless they decline that status. Retail investors are excluded.
The rules that remain
- Labelling: the fund must be identified as a “Limited Qualified Investor Fund” or “L-QIF” on the front page of its documents and in advertising, and investors must be told clearly that it is not authorised or supervised by FINMA.
- Investment rules: the Act sets no specific list of permitted investments or diversification rules. The fund documents must set them out, and the fund must follow them.
- Liquidity: the liquidity requirements apply from the first day, matched to the asset class, the investment policy and the redemption frequency.
- Audit: an audit of the accounts, plus a supplementary audit checking that the fund still meets the L-QIF criteria.
- Register: the Federal Department of Finance keeps a public list of all L-QIFs.
- No “real estate fund” label: an L-QIF investing in real estate may not call itself a real estate fund.
Who it suits
- Swiss managers who want a Swiss fund for their professional clients without waiting for a FINMA approval.
- Family offices and private equity teams pooling capital from qualified investors.
- Strategies that do not fit the standard fund categories.
Who it does not suit: anyone who wants to sell to retail investors, or a manager without the right FINMA licence. For that step, see our portfolio manager licence guide and the complete map of Swiss financial licences.
Read the full series
This article is part of our series on launching and managing funds in Switzerland:
- The L-QIF: Switzerland’s fund without FINMA approval, and what it really requires (you are reading it)
- Who counts as a qualified investor in Switzerland? The gate to the L-QIF
- Managing funds in Switzerland: manager of collective assets or fund management company?
- Buy and upgrade, or start fresh? The fastest route to a Swiss CISA licence
- Buying a Swiss regulated company: what to check before you sign
Ask us whether an L-QIF fits your strategy, or write to insight@fintechlex.com.
This article is for general information only and does not constitute legal advice.
