For years, a Swiss crypto business had one regulatory question: which SRO do I join? That question is changing. The new one is: which licence, in which company, and when?
If you run a crypto business from Asia, Europe or the Gulf and want a Swiss base, this is what you need to know before you buy or build anything.
What a crypto SRO company can do today
Under Swiss anti-money laundering law, exchanging crypto-assets against money or other crypto-assets, transferring them for clients and holding them for clients all make you a financial intermediary. For many crypto business models, SRO membership covers the anti-money laundering side, and it is the fastest way to operate legally in Switzerland as a virtual asset service provider (VASP). Some set-ups, such as certain forms of custody, may already need a FINMA licence, depending on the assets and how they are held.
You don’t have to build everything yourself either. Most founders start with software that comes with liquidity, or with a white-label solution where a regulated partner provides the platform, the execution and often the custody. The anti-money laundering duties stay with you, but the hardest technical work doesn’t.
What the SRO will expect is that you apply the crypto rules properly: identification of occasional exchange clients from CHF 1,000, including linked transactions (clients in a lasting business relationship are identified from the first franc); the travel rule on crypto transfers; sanctions screening of wallets, not only names; and a clear answer to the question every auditor and bank asks: who holds the keys?
What the reform will change
In October 2025, the Federal Council opened a consultation on a reform of the Financial Institutions Act. It creates two new FINMA licences: the payment instrument institution, which replaces today’s FinTech licence, and the crypto institution. It is still a draft and details may change, but the direction is clear.
What would move to the new crypto licence: custody of crypto-assets for clients, trading for clients in your own name, and market making (quoting prices to the public on a continuous basis or on request), the core of most crypto business models.
What would stay outside it: pure proprietary trading without quoting prices to the public, crypto portfolio management, non-custodial wallets and brokerage of Swiss stablecoins in the narrow sense defined by the draft (stablecoins issued abroad do not benefit from this exclusion). Where they qualify as financial intermediation, the SRO stays. Payments, exchange and the other traditional SRO activities are not the target of the crypto licence.
The transition: under the draft, a crypto broker or custodian operating under an SRO would have one year from entry into force to apply to FINMA and meet the new requirements, and could keep operating until FINMA decides, but only if it stays affiliated with its SRO and supervised by it.
Why buying an SRO company now makes sense
That last condition is the key. Under the draft, the companies that will cross over smoothly are the ones that are already operating, already in an SRO, with clean files and a track record when the new rules arrive. A company that starts from scratch after the reform has to build all of that before it can even file.
FINMA gives no priority to anyone. But the founders who have complete files and an audited history will be ready to file on day one, while the others are still putting their documents together.
So the SRO is still the way to start: you operate now, you build your track record and your banking relationships now, and you prepare the licence file from a position of strength. Buying an existing SRO company saves you the months of admission, and if it comes with accounts already open, it also saves you the hardest part.
What you buy matters, though. Check what the company actually does. A company whose activities stay outside the new licence may keep its value for a buyer who wants to run those activities. One that needs the licence means a preparation and licensing project, which is fine, as long as you know it before you pay.
Swiss SRO companies for sale
FintechLex currently has Swiss SRO companies for sale, including a company in Zug affiliated with SO-FIT, with accounts already open with two payment institutions. We check what each company does, where it stands against the reform, and how to prepare its future FINMA file.
For the full picture, read What Nobody Tells You About the Swiss SRO in 2026. Chapters 14 and 15 cover crypto SRO companies and the reform.
Write to us at insight@fintechlex.com or on WhatsApp +41 787 983 770.
Rene-Philippe
