FinTech licence (Persons pursuant to Article 1b Banking Act (Switzerland)
The FinTech licence (Persons pursuant to Article 1b Banking Act / FinTech-Bewilligung nach Art. 1b BankG) is issued by Swiss Financial Market Supervisory Authority (FINMA) under Federal Act on Banks and Savings Banks (Banking Act, BankA, SR 952.0). The official register lists 6 current holders. The legal decision period is No statutory decision deadline prescribed in Swiss administrative law (FINMA examines applications once complete documentation and regulatory audit report are submitted).
At a glance
| Official name | FinTech licence (Persons pursuant to Article 1b Banking Act1 |
|---|---|
| Local name | FinTech-Bewilligung nach Art. 1b BankG) |
| Also known as | Swiss FinTech licence · Art. 1b BankG licence · Banking Act Article 1b licence · FINMA FinTech licence · FinTech-Bewilligung · Swiss banking licence light |
| Issued by | Swiss Financial Market Supervisory Authority |
| Jurisdiction | Switzerland |
| Licence family | Bank / credit institution |
| Legal basis | Federal Act on Banks and Savings Banks (Banking Act, BankA, SR 952.0)2 Ordinance on Banks and Savings Banks (Banking Ordinance, BankO, SR 952.02)3 |
| Passporting | Domestic only |
| Application fee | CHF 100 to 500 per hour of work (Art. 8 FINMA-GebV)4 |
| Annual fee | CHF 3,000 fixed base levy (Art. 19e FINMA-GebV) plus supplementary levy based on balance sheet total and gross income (Art. 19f FINMA-GebV)5 |
| Statutory decision time | No statutory decision deadline prescribed in Swiss administrative law (FINMA examines applications once complete documentation and regulatory audit report are submitted)1 |
| Public register | official register6 |
| Current holders | 66 |
What it lets you do, and where
Activities it covers
| Taking deposits from the public | Accepting deposits or other repayable funds from the public, the activity reserved to credit institutions. |
|---|---|
| Lending | Granting loans, including consumer credit, mortgage credit, factoring and financing of commercial transactions. |
| Execution of payment transactions | Executing direct debits, card payments and credit transfers, including standing orders, from a payment account. |
Where it is valid
Do you need it, and is Switzerland the right choice?
What is a Swiss FinTech licence and do you actually need one?
A Swiss FinTech licence is the authorisation regime for persons under Article 1b of the Banking Act. It allows commercial deposit-taking up to CHF 100 million, provided the deposits are neither reinvested nor bear interest. BankV also requires Art. 1b BankG persons to keep public deposits and collectively custodied crypto-based assets segregated from their own funds.2114
Is a Swiss FinTech licence right for your model, and what are the alternatives?
It depends on how you hold client money. The Banking Act separates FinTech deposit-taking up to CHF 100 million without reinvestment (Art. 1b) from full banking (Art. 1a), and a Swiss decision tree distinguishes SRO brokerage, FinTech custody and full banking. Under a planned FINIG revision replacing the FinTech licence, payment instrument institutions would be exempt from the CHF 100 million limit.101516
Swiss SRO membership or a FINMA FinTech licence, which does your crypto model need?
It turns on deposit-taking. The FinTech licence under BankA Art. 1b covers accepting public deposits or designated crypto assets up to CHF 100 million that are neither invested nor bear interest. Settlement accounts are exempt from deposit-taking for a maximum of 60 days (BankO Art. 5 para. 3 let. c no. 1). Financial intermediaries under AMLA Art. 2 para. 3 are supervised by affiliated SROs rather than FINMA.101417
What changes with the 2026-27 Swiss financial market reform for FinTech licence holders?
The Federal Council opened consultation on 22 October 2025 (running until 6 February 2026) on amending the Financial Institutions Act (FinIA). The proposal replaces the Art. 1b BankA FinTech licence with a new Payment Instrument Institution licence that removes the CHF 100 million limit and makes client funds segregable in bankruptcy, alongside a new Crypto Institution licence. Entry into force is possible from 2027 at the earliest.181619
What it really takes
How much capital do you really need for a Swiss FinTech licence?
For a Swiss FinTech licence, the minimum capital is 3% of deposits, with a floor of CHF 300,000, fully paid in (BankO Art. 17a). In practice, FINMA expects capital that covers 12 months of operating expenses, which amounts to roughly CHF 1,000,000.1413
Who do you have to hire for a Swiss FinTech licence, and where must they be based?
Your entity must be effectively managed from Switzerland, and managers must reside where that management can actually be exercised (BankO Art. 14c). Expect at least two local executive directors and board presence. Under FINMA Circular 2018/3, core executive and control functions may not be outsourced; other functions can be.142013
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | Federal Act of 8 November 1934 on Banks and Savings Banks (Banking Act, BankA) | Establishes the FinTech licence (Art. 1b), sets statutory thresholds (CHF 100M deposits, prohibition on investing deposits and paying interest), licensing prerequisites (fit & proper, minimum capital, local presence), and criminal sanctions (Art. 46, 49). |
| Act | Federal Act of 22 June 2007 on the Swiss Financial Market Supervisory Authority (Financial Market Supervision Act, FINMASA, SR 956.1) | Establishes FINMA's supervisory architecture, regulatory audit mandates, investigatory and enforcement instruments, and criminal penalties for unlicensed commercial activity (Art. 44) or false representations (Art. 45). |
| Secondary legislation | Ordinance of 30 April 2014 on Banks and Savings Banks (Banking Ordinance, BankO, SR 952.02) | Executes BankA Art. 1b with detailed organisational conditions (Art. 14a-14g), minimum capital of 3% or CHF 300,000 (Art. 17a), client risk disclosures (Art. 7a), deposit liquidity segregation (Art. 14f), and prior-approval requirements for material changes (Art. 8a). |
| Regulator rules | FINMA Circular 2023/1 'Operational risks and resilience: banks' | Sets binding principles on operational risk management, ICT risk, cyber resilience, critical data security, and business continuity management (BCM) applied mutatis mutandis to FinTech entities. |
| Regulator rules | FINMA Circular 2018/3 'Outsourcing: banks and insurers' | Governs mandatory risk analysis, contractual requirements, inventorying, and audit and supervisory access rights when outsourcing essential business functions. |
| Regulator rules | FINMA Circular 2016/7 'Video and online identification' | Establishes binding technical and organizational standards for digital customer onboarding and video/online identification under AML due diligence regulations. |
| Procedure law | Federal Act of 20 December 1968 on Administrative Procedure (Administrative Procedure Act, APA / VwVG, SR 172.021) | Governs FINMA administrative licensing proceedings, official procedural languages (Art. 33a), right to be heard (Art. 29-32), electronic filing (Art. 21a), and delay remedies (Art. 46a). |
| Procedure law | Federal Act of 17 June 2005 on the Federal Administrative Court (Administrative Court Act, FACCA / VGG, SR 173.32) | Designates the Federal Administrative Court as the competent judicial forum to adjudicate appeals against FINMA licensing decisions and formal administrative rulings (Art. 31, Art. 33 let. e). |
| Fee schedule | Ordinance of 15 October 2008 on the Levying of Fees and Levies by the Swiss Financial Market Supervisory Authority (FINMA Fee Ordinance, FINMA-GebV, SR 956.122) | Establishes hourly application processing fees of CHF 100 to 500 (Art. 8) and annual supervisory levies (CHF 3,000 fixed base levy under Art. 19e plus variable levy under Art. 19f). |
| Forms | FINMA FinTech Application Forms and Declarations Suite (EHP Portal: Forms A1, A2, A3/A4, B1, B2, B3, Change of Guarantor Form) | Mandatory standard questionnaires and declarations submitted electronically via the FINMA EHP platform for institutional applicants, qualified participants, and governing bodies. |
8 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | FINMA Guidelines for applications for a FinTech licence pursuant to Article 1b of the Banking Act (version of 24 April 2025) | Details licensing application dossier structure, governance expectations, financial requirements, crypto custody disclosures, and lists prior-approval triggers. |
| Guidance | FINMA Guidance 08/2019 'Payment transactions on the blockchain' | Sets supervisory expectations for applying AMLO-FINMA Art. 10 (Travel Rule) to crypto-asset transfers, requiring exchange of verified customer identity details without unverified third-party wallets. |
| Guidance | FINMA Audit Confirmation Guidance and Report Form (Wegleitung für der FINMA einzureichende Bestätigungen der Prüfgesellschaften zu Gesuchen betreffend Institutsbewilligungen 'Fintech-Unternehmen') | Defines the scope, criteria, and standard template for the independent regulatory audit firm's pre-licensing examination report (Prüfbericht). |
| Related regime | Federal Act of 10 October 1997 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA) | Subjects FinTech licence holders to statutory AML/CFT obligations as directly FINMA-supervised financial intermediaries, including customer identification, beneficial owner verification, and mandatory MROS reporting (Art. 2 para. 2 let. a, Art. 9). |
| Related regime | Ordinance of 11 November 2015 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Ordinance, AMLO, SR 955.01) | Specifies secondary federal due diligence requirements and thresholds for the professional practice of financial intermediation. |
| Related regime | FINMA Ordinance of 3 June 2015 on Combating Money Laundering and Terrorist Financing in the Financial Sector (FINMA Anti-Money Laundering Ordinance, AMLO-FINMA, SR 955.033.0) | Sets binding AML requirements for directly supervised intermediaries, including transaction monitoring, politically exposed persons (PEPs) controls, and virtual asset transfer / Travel Rule compliance (Art. 10). |
| Related regime | Federal Act of 15 June 2018 on Financial Services (Financial Services Act, FinSA, SR 954.1) | Governs point-of-sale conduct rules, client segmentation, information duties, documentation, and mandatory ombudsman affiliation if financial services are provided to clients. |
| Related regime | Federal Act of 25 September 2020 on the Adaptation of Federal Law to Developments in Distributed Electronic Registers (DLT Act, AS 2021 33) | Enacted amendments integrating crypto-based assets, collective custody, and domestic segregation regimes into BankA Art. 1b and BankO Art. 5a and 14f. |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | Application templates are available on FINMA's survey and application platform (EHP); applicants must self-register via the FINMA homepage and, once verified, access the EHP through the FINMA portal using two-factor authentication.17 | Administrative Procedure Act (APA / VwVG, SR 172.021) Art. 21a; Financial Market Supervision Act (FINMASA / FINMAG, SR 956.1) Art. 29; Ordinance of 18 June 2010 on Electronic Transmission in Administrative Proceedings (VeÜ-VwV, SR 172.021.2) |
| Language | Applications must be filed in one of Switzerland's official languages or in English. However, the articles of association, the organisational regulations and any other documents subject to approval must be submitted in one of Switzerland's official languages.8 | |
| What the application contains | FINMA's Guidelines for applications for a FinTech licence under Article 1b of the Banking Act highlight the information and documents an applicant must usually submit; FINMA may request further details. Applications may be in an official language or English, but articles of association, organisational regulations and other approval-subject documents must be in an official language. FINMA's website lists forms A4, B1, B2, B3, a Gewährsträger change form on the EHP, and an audit report FINMA may request case by case.18 | Banking Act (BankA, SR 952.0) Art. 1b & Art. 3; Banking Ordinance (BankO, SR 952.02) Art. 8, Art. 8a & Section 1b (Art. 14a-14g); FINMA Guidelines for applications for a FinTech licence (version 24 April 2025), sections I.1-I.7 |
| Decision clock | Duration depends on project complexity and application quality and completeness. Statutory periods cannot be extended; authority-set periods may be extended on reasonable grounds if requested before expiry.19 | |
| Fees set by law | Licence application processing fee: CHF 100 to 500 per hour of FINMA staff time; Annual supervisory base levy (Grundabgabe): CHF 3,000; Annual supervisory supplementary levy (Zusatzabgabe): CHF Variable based on balance sheet total and gross revenue5 | Ordinance of 15 October 2008 on the Levying of Fees and Levies by the Swiss Financial Market Supervisory Authority (FINMA Fee Ordinance, FINMA-GebV, SR 956.122), Art. 8, Art. 19e, Art. 19f |
| Grounds for refusal | They only describe licence requirements (e.g. CHF 100 million deposit cap, no interest or lending, CHF 300,000 capital, Swiss domicile and corporate form) and note that providing false information to FINMA is an offence under Art. 45 FINMASA.1081 | |
| Appeal | A refusal by FINMA can be appealed to the Federal Administrative Court (Bundesverwaltungsgericht), which is listed as an appellate authority under Articles 31-34 of the Administrative Court Act. The Administrative Procedure Act governs the procedure.119 | Federal Act on the Swiss Federal Administrative Court (Administrative Court Act, FACCA / VGG, SR 173.32) Art. 31, Art. 33 let. e; Administrative Procedure Act (APA / VwVG, SR 172.021) Art. 44, Art. 50 para. 1. A further appeal on questions of federal law lies to the Federal Supreme Court (Bundesgericht) under the Federal Supreme Court Act (FSCA / BGG, SR 173.110) Art. 82 let. a within 30 days. |
| Validity | They only note that changes affecting licensing require prior FINMA authorisation or approval, and that licensing requirements must be complied with at all times. No renewal procedure or licence duration is described.1812 | |
| Change of control | Any change to the basis on which the licence was granted must be reported to FINMA. For material changes, authorisation must be obtained from FINMA before continuing with operations (Art. 8a BO).8 | |
| Reapplying after a refusal | None of the governing texts held for this licence (Federal Act of 8 November 1934 on Banks and Savings Banks (Banking Act, BankA); Federal Act of 8 November 1934 on Banks and Savings Banks (Banking Act, BankA); Ordinance on Banks and Savings Banks (Banking Ordinance, BankO); Ordinance on Banks and Savings Banks (Banking Ordinance, BankO); Federal Act of 10 October 1997 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA); Federal Act of 10 October 1997 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA); Federal Act of 15 June 2018 on Financial Institutions (Financial Institutions Act, FinIA); Federal Act of 15 June 2018 on Financial Institutions (Financial Institutions Act, FinIA); Federal Act on Collective Investment Schemes (Collective Investment Schemes Act); Federal Act on Collective Investment Schemes (Collective Investment Schemes Act); Federal Act of 19 June 2015 on Financial Market Infrastructures and Market Conduct in Securities and Derivatives Trading (Financial Market Infrastructure Act, FinMIA); Federal Act of 19 June 2015 on Financial Market Infrastructures and Market Conduct in Securities and Derivatives Trading (Financial Market Infrastructure Act, FinMIA)) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | The FinTech licence holder must have its registered office and conduct its business activities in Switzerland (Banking Act Art. 1b). Serving clients abroad is possible on a reverse-solicitation basis, with the initiative coming exclusively from the client; direct solicitation requires compliance with the recipient country's cross-border rules, a cross-border policy and country manuals, and the geographic scope must be defined in the Organisational Business Regulation.113 |
How long it takes
How long does it really take to get a Swiss FinTech licence?
Plan for one to two years. Duration depends on the complexity of the project and on the quality and completeness of the application. If FINMA unlawfully refuses or delays a contestable ruling, an appeal may be filed under APA Art. 46a.1913
What it costs
What does a Swiss FinTech licence cost in total, first year and ongoing?
FINMA charges CHF 100 to 500 per hour (FINMA-GebV Art. 8), plus a base annual levy of CHF 3,000 (Art. 19e) and a variable levy (Art. 19f). FinTech licensees also face regulatory audit and compliance mandates under Art. 1b BankA.1021
Approval odds and who can own it
What are the real approval odds for a Swiss FinTech licence, and why do applications fail?
As of September 2026, FINMA's register lists 6 licensed persons under Article 1b Banking Act (FinTech licence). Historic holders have not all survived: FINMA opened bankruptcy proceedings over SWISS4.0 SA on 4 March 2025 due to overindebtedness and liquidity distress, and Mogli AG was liquidated in 2022.6222324
After you get the licence
Alongside the licence, financial service providers must be affiliated to an ombudsman's office (FinSA Art. 74), which under the transitional provision Art. 95 para. 3 had to be in place within six months of the Act coming into force. Crypto transfers also carry Travel Rule data transmission duties (AMLO-FINMA Art. 10, FINMA Guidance 02/2019), and multilateral tokenised securities trading needs DLT trading facility authorisation (FinfraG Art. 73a).252627
Will you get a bank account and payment processing with a Swiss FinTech licence?
A Swiss FinTech licence lets a company open an SNB sight deposit account and access the SIC payment system directly, without an intermediary bank. Separately, many Swiss banks offer accounts to crypto companies, but not to every company, and many banks apply de-risking policies that refuse high-reputational-risk sectors a priori.132829
Keeping the licence involves a regulatory audit: persons subject to audit under Art. 24 FINMASA must have their annual and consolidated accounts audited by a state-supervised audit firm (Code of Obligations; CISA Art. 126 para. 5). A Federal Council consultation opened on 22 October 2025 proposes to replace the fintech licence with Payment Institutions and Crypto Institutions under FinIA, and upcoming payment token rules abolish the CHF 100 million cap.1930
Buying a company that already holds it
Prior approval required. A qualifying participation is defined as directly or indirectly holding at least 10% of the capital or voting rights, or otherwise exerting a significant influence over the company (BankA Art. 3 para. 2 let. c; FinIA Art. 11 para. 1). Notification to FINMA is mandatory prior to acquiring, disposing of, or reaching, exceeding, or falling below the statutory thresholds of 10%, 20%, 33%, or 50% (BankA Art. 3 para. 5; BankO Art. 8a; FinIA Art. 11 para. 4). For FinTech licence holders (Art. 1b BankA), FINMA's FinTech Licensing Guidelines explicitly mandate prior formal approval before completing any change in qualified participations. Furthermore, when foreign control is established or modified in a Swiss bank or securities firm, a supplementary licence (Zusatzbewilligung) is mandatory under BankA Art. 3bis. For SRO-affiliated financial intermediaries, Art. 6 para. 2 of SRO regulations (e.g. VQF) mandates prior written notice and SRO approval before transferring qualified holdings.1
Bank in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Abu Dhabi Global Market (ADGM) | Financial Services Permission for Accepting DepositsFinancial Services Permission for Accepting Deposits (Category 1 Commercial Bank) | FSRA | n/a | USD 70,000 | n/a |
| Bermuda | Banking Licence / Deposit Company Licence / Restricted Banking LicenceBanking Licence / Deposit Company Licence / Restricted Banking Licence (Banks and Deposit Companies Act 1999) | BMA | n/a | n/a | n/a |
| Cayman Islands | Bank LicenceBank Licence (Category A and Category B) under the Banks and Trust Companies Act | CIMA | n/a | n/a | n/a |
| Czech Republic | Commercial Bank licence | CNB | n/a | CZK 200,000 | n/a |
| Dubai International Financial Centre (DIFC) | Bank licenceFinancial Services Permission for Accepting Deposits or Providing Credit (Category 1 Commercial Bank) | DFSA | n/a | USD 70,000 | n/a |
| Estonia | Credit institution authorisation (bank) | FI | n/a | EUR 5,000 | ~6 mo |
| Georgia | Commercial bank licence | NBG | n/a | n/a | ~6 mo |
| Germany | CRR) | BaFin | n/a | n/a | ~6 mo |
| Ireland | Banking LicenceBanking Licence (Section 9 Central Bank Act 1971) | CBI | n/a | n/a | ~6 mo |
| Latvia | Credit institution licence (bank) | LB | n/a | n/a | 4-13 mo |
| Lithuania | Specialised bank licence | LB | n/a | EUR 4,157 | ~6 mo |
| Lithuania | Bank licence | LB | n/a | n/a | n/a |
| Luxembourg | Credit institution authorisation | CSSF | n/a | EUR 75,000 | ~6 mo |
| Malta | Credit institution licence | MFSA | n/a | EUR 35,000 | ~6 mo |
| Netherlands | Bank licenceBank licence (Vergunning bank / kredietinstelling) | DNB | n/a | EUR 44,300 | ~6 mo |
| Poland | Commercial Bank licence | KNF | n/a | n/a | n/a |
| Singapore | Banking LicenceBanking Licence (Full Bank, Wholesale Bank, Digital Bank) | MAS | n/a | n/a | n/a |
| Slovakia | Banking licence | NBS | n/a | n/a | n/a |
| Spain | Commercial bank licence | BdE | n/a | n/a | ~6 mo |
| Switzerland | FinTech licence (PersonsFinTech licence (Persons pursuant to Article 1b Banking Act | FINMA | n/a | CHF 100 | n/a |
| Switzerland | Banking licence | FINMA | n/a | n/a | n/a |
| United Arab Emirates | Commercial Bank Licence | CBUAE | n/a | n/a | n/a |
Values come from each licence's page, where every figure has its source.
Laws behind it
Frequently asked questions
What is a Swiss FinTech licence and do you actually need one?
A Swiss FinTech licence is the authorisation regime for persons under Article 1b of the Banking Act.
How much capital do you really need for a Swiss FinTech licence?
For a Swiss FinTech licence, the minimum capital is 3% of deposits, with a floor of CHF 300,000, fully paid in (BankO Art. 17a).
How long does it really take to get a Swiss FinTech licence?
Plan for one to two years. Duration depends on the complexity of the project and on the quality and completeness of the application. If FINMA unlawfully refuses or delays a contestable ruling, an appeal may be filed under APA Art. 46a.
What does a Swiss FinTech licence cost in total, first year and ongoing?
FINMA charges CHF 100 to 500 per hour (FINMA-GebV Art. 8), plus a base annual levy of CHF 3,000 (Art. 19e) and a variable levy (Art. 19f).
What are the real approval odds for a Swiss FinTech licence, and why do applications fail?
As of September 2026, FINMA's register lists 6 licensed persons under Article 1b Banking Act (FinTech licence).
Will you get a bank account and payment processing with a Swiss FinTech licence?
A Swiss FinTech licence lets a company open an SNB sight deposit account and access the SIC payment system directly, without an intermediary bank.
Who do you have to hire for a Swiss FinTech licence, and where must they be based?
Your entity must be effectively managed from Switzerland, and managers must reside where that management can actually be exercised (BankO Art. 14c).
Is a Swiss FinTech licence right for your model, and what are the alternatives?
It depends on how you hold client money. The Banking Act separates FinTech deposit-taking up to CHF 100 million without reinvestment (Art. 1b) from full banking (Art. 1a), and a Swiss decision tree distinguishes SRO brokerage, FinTech custody and full banking. Under a planned FINIG revision replacing the FinTech licence, payment instrument institutions would be exempt from the CHF 100 million limit.
Swiss SRO membership or a FINMA FinTech licence, which does your crypto model need?
It turns on deposit-taking. The FinTech licence under BankA Art. 1b covers accepting public deposits or designated crypto assets up to CHF 100 million that are neither invested nor bear interest. Settlement accounts are exempt from deposit-taking for a maximum of 60 days (BankO Art. 5 para. 3 let. c no. 1). Financial intermediaries under AMLA Art. 2 para. 3 are supervised by affiliated SROs rather than FINMA.
What changes with the 2026-27 Swiss financial market reform for FinTech licence holders?
The Federal Council opened consultation on 22 October 2025 (running until 6 February 2026) on amending the Financial Institutions Act (FinIA).
Sources
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