By Rene Philippe Raymond Dubout · · Updated Can you take money from clients in Switzerland without a banking licence? Yes, up to CHF 1 million, and Bern wrote it into the law on purpose. Since 2017, the Banking Ordinance has contained what everybody calls the “sandbox”: a small, licence-free space where a fintech can hold client money and test its model before it spends a fortune on FINMA. It is still the cheapest door into Swiss regulated finance. It is also the most misunderstood one.
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I have read sandbox descriptions that promise you can run a financial business “without any authorisation and without any supervision”. That is wrong, and I say it with some humility, because one of those descriptions sat on our own old blog. So here is what the sandbox really allows, what it does not, and what happens on the day you outgrow it.
What the sandbox actually is
Under Swiss banking law, whoever accepts deposits from the public on a professional basis needs a banking licence. “Professional” means, in principle, more than 20 depositors, or advertising for deposits. Article 6, paragraph 2, of the Banking Ordinance carves out an exception: you are not acting professionally, even with more than 20 depositors, if you meet four conditions.
- The ceiling. The total of the public deposits you hold, together with any cryptoassets you keep in collective custody for clients, does not exceed CHF 1 million.
- No interest business. You do not run an interest business with that money. In plain words, you do not lend it out or invest it to live on the spread, which is the bank’s classic trade.
- A warning before the money arrives. Before each client deposits, you tell him, in writing or in another form that leaves a text trail, that you are not supervised by FINMA.
- No deposit insurance. In the same warning, you tell him that his deposit is not covered by the Swiss deposit protection scheme.
That is the whole sandbox. There is no application to file, no register to join and no FINMA approval to wait for. You meet the conditions, or you are running an unlicensed bank. In other words, it is a speed limit, not a parking permit: nobody gives it to you, and nobody takes it away, as long as you stay under it.
What the sandbox does not do
This is where most founders get burnt. The sandbox is an exception to the Banking Act, and only to the Banking Act. It does not switch off the rest of Swiss financial law.
- Anti-money laundering still applies. If you accept or hold client money, transfer it, exchange currencies or crypto, you are very likely a financial intermediary under the Anti-Money Laundering Act. That means joining a self-regulatory organisation (SRO) recognised by FINMA, with its audits and its rules, from the first client. The sandbox and the SRO are not alternatives: most sandbox businesses need both.
- Other licences still apply. Managing client portfolios, dealing in securities, running a collective investment scheme or a trading venue each has its own licence. The sandbox covers none of them.
- Your clients carry the risk. If the company fails, a sandbox client is an ordinary creditor, with no privilege and no deposit insurance. That is exactly why the law forces you to tell him in advance.
- It does not open a bank account for you. A Swiss bank will ask the same questions it asks any fintech: who owns it, where the money comes from, which SRO supervises it. A sandbox company with no SRO and no track record is not a bank’s favourite client.
What happens when you pass CHF 1 million
The ceiling is not a soft target. The day you go above it, Article 6, paragraph 4, of the Banking Ordinance gives you 10 days to report it to FINMA and 30 days to file a licence application. If the protection of depositors requires it, FINMA can forbid you to accept new deposits until it has decided. A successful test can therefore turn into a frozen business in a few weeks, which is an odd reward for success.
So the sandbox is a beginning, not a destination. Before you reach the ceiling, you need to know where you are going next: a structure where client money sits with a bank or a licensed partner, the fintech licence of Article 1b of the Banking Act, a full banking licence, or a licensed entity in the European Union. Which one depends on your model, and that decision is better taken at CHF 500,000 than at CHF 999,000.
Setting up a sandbox company
The sandbox is not a type of company. Any Swiss company that meets the four conditions is in it. In practice, founders use one of the two usual forms:
- A company limited by shares (AG/SA): minimum capital of CHF 100,000, of which at least CHF 50,000 must be paid in at incorporation.
- A limited liability company (GmbH/Sàrl): minimum capital of CHF 20,000, fully paid in.
- In both cases, the company must be represented by at least one person who lives in Switzerland, which foreign founders often discover late.
Then come the SRO affiliation, the anti-money laundering procedures, the client warning text, and the bank account. None of this is exotic, but each step takes time, and the bank account takes the longest.
Can you buy a “sandbox”?
Not as such, and anyone who sells you one is selling you something you already have. Every Swiss company enjoys the sandbox exception the moment it meets the conditions. Our own 2024 listing carried the title “Swiss FinTech Sandbox for Sale”; the honest description would have been “Swiss company for sale, ready to use the sandbox”.
What does have value is the company around it: incorporated, capitalised, already affiliated with an SRO, with procedures that work and, ideally, a bank account. That is what saves you months. For a business that will hold client money, buying an existing SRO-affiliated company and running it inside the sandbox limits is often the fastest legal start in Switzerland. The new owners still have to be accepted by the SRO and by the bank, so it is faster, not magic.
Is the sandbox affected by the 2026 reform?
The Federal Council’s consultation draft of October 2025 proposes to replace the fintech licence with a payment instrument institution licence, and to bring crypto custody and dealing under a new crypto institution licence. The sandbox itself sits in the Banking Ordinance, and the implementing ordinances for the reform have not been published yet. Nobody can therefore tell you today whether the CHF 1 million door will stay exactly as it is once the new licences arrive. Until then, today’s rules apply, and we will update this article when the ordinances are out.
For the two proposed licences in detail, read our article Two New Swiss Fintech Licences: Get Ready First, and for the comparison with the fintech licence and an EU EMI, see SRO, Fintech Licence or EU EMI?
The route we recommend
If you want to test a business that holds client money in Switzerland, start with three questions. Does your model fit under CHF 1 million for the test? Which SRO will supervise you? Where will the client money sit the day you pass the ceiling? If you can answer all three, the sandbox is an excellent, cheap start. If you cannot, you are not testing a business, you are testing your luck.
FintechLex has SRO-affiliated companies for sale and handles the rest: the SRO procedure for the new owners, the client warning and procedures, the bank account, and the plan for the day you outgrow the sandbox. Tell us what you want to test and with whom, and we will tell you whether the sandbox fits, before you spend a franc. Write to insight@fintechlex.com, or see the companies currently for sale in our Marketplace. For the SRO route in detail, see our Swiss SRO Licence 2026 guide.
Looking to set up or buy a Swiss company with SRO affiliation? See our Swiss SRO licence and company acquisition service.
This article is for general information only and does not constitute legal advice.
Sources
- Banking Ordinance (BankO, SR 952.02), Article 6, paragraphs 1, 2 and 4, version in force since 1 January 2025, checked on Fedlex on 23 October 2026.
- Banking Act (BankA, SR 952.0), Articles 1, 1a and 1b.
- Anti-Money Laundering Act (AMLA, SR 955.0), Article 2, paragraph 3 (financial intermediaries), and Article 14 (SRO affiliation).
- Swiss Code of Obligations, Articles 621, 632, 718 paragraph 4, 773 and 814 paragraph 3 (minimum capital and Swiss-resident representation).
- Federal Council, consultation draft amending the Financial Institutions Act and explanatory report, 22 October 2025.
