Financial intermediary / VASP SRO affiliation (Switzerland)
A Swiss VASP that does not take deposits or pooled custody creating a claim against itself does not need a FINMA licence: it affiliates with a FINMA-recognised SRO (e.g. VQF or PolyReg, both of which admit crypto/VASP members) under AMLA instead. There is no minimum capital; admission turns on good reputation and a working AML/CFT organisation, with SRO fees from roughly CHF 1,200-5,800.
At a glance
| Official name | Financial intermediary / VASP SRO affiliation1 |
|---|---|
| Local name | Finanzintermediär nach Art. 2 Abs. 3 GwG (Anschluss an eine Selbstregulierungsorganisation, SRO) |
| Also known as | SRO · SRO membership · Swiss SRO-regulated company · Swiss SRO VASP · Finanzintermediär · GwG financial intermediary |
| Market names to check | Swiss VASP licence: Switzerland has no VASP licence; this is AML affiliation with an SRO, not a FINMA authorisation Swiss crypto licence: SRO affiliation is AML supervision, not a licence to operate |
| Issued by | Swiss Financial Market Supervisory Authority |
| Jurisdiction | Switzerland |
| Licence family | Virtual asset service provider (non-MiCA) |
| Legal basis | Federal Act on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA, SR 955.0)2 AMLA/GwG Art. 2 para. 3 defines the non-prudentially-supervised financial intermediaries this licence covers (payment services, crypto brokers, custodians without a banking claim); Art. 14 requires them to affiliate with a FINMA-recognised SRO instead of holding a FINMA licence directly.1 |
| Passporting | Domestic only |
| Minimum capital | No statutory minimum capital for AMLA/GwG financial intermediaries affiliating with an SRO. Neither VQF's nor PolyReg's own admission criteria include a capital threshold: both instead condition membership on the good reputation of the persons responsible for business conduct and on having a working AML/CFT organisation. A capital requirement only arises if the business instead needs a FINMA licence (e.g. a banking licence, which requires CHF 10 million minimum capital).3 |
| Application fee | SRO admission fees vary by SRO. PolyReg (a FINMA-recognised SRO that explicitly accepts Virtual Asset Service Providers) charges CHF 1,600 for a standard financial-intermediary member, or CHF 1,200 for an inactive/voluntary member; VASP applicants must also undergo a mandatory in-person pre-admission audit at additional hourly cost, with no postponement granted given crypto's elevated risk classification. A secondary source separately reports VQF's admission fee at around CHF 2,000.3 |
| Annual fee | PolyReg's published annual membership fee ranges from CHF 1,400 to CHF 5,800 depending on business size and membership status, plus recurring AML audit costs billed at CHF 250/hour, a one-off CHF 600 basic training fee, and CHF 400/year for continuing education.3 |
| Statutory decision time | No statutory decision deadline for SRO admission. VQF's own FAQ states it cannot give a binding processing time, since duration depends on how complete the application file is and how quickly the admission fee and documentation are provided.4 |
| Public register | official register5 |
What it lets you do, and where
What does a Swiss VASP SRO affiliation let you do, and where can you serve clients?
SRO affiliation covers financial intermediation activities, including virtual currency transmission, under AMLA Art. 2 para. 3 and AMLO Art. 4. Holding client fiat is limited to omnibus settlement accounts cleared within a maximum of 60 days (BankO Art. 5 para. 3 let. c no. 1). Switzerland sits outside the EEA, so Swiss entities cannot MiCA-passport into the European Union.181911
Activities it covers
| Virtual asset exchange (FATF) | Exchanging virtual assets for fiat currency or for other virtual assets as a business, as defined in the FATF glossary. |
|---|---|
| Virtual asset transfer (FATF) | Conducting transactions that move virtual assets between addresses or accounts on behalf of another person. |
| Virtual asset safekeeping (FATF) | Safekeeping or administering virtual assets, or instruments enabling control over them, for another person. |
Where it is valid
Do you need it, and is Switzerland the right choice?
What is a Swiss VASP SRO affiliation and do you actually need one?
Yes, if you act as a financial intermediary. SRO affiliation is a statutory AML registration, not a banking licence. Under AMLA Art. 2 para. 3, financial intermediaries must affiliate with a recognised SRO (Art. 14 para. 1). Direct FINMA AML supervision (DUFI) was abolished on 1 January 2020, so non-bank intermediaries are channelled to SROs. No banking licence is needed if virtual currencies are stored separately per customer and attributable at all times; such custody is AMLA-regulated.2206
Is a Swiss SRO affiliation right for your model, and what are the alternatives?
A Swiss crypto licensing decision tree separates SRO brokerage, FinTech custody and full banking. A full Swiss banking licence carries expected capital of CHF 20M+ and an all-in setup cost of CHF 25 to 35M. Under BankV Art. 5, client account balances of precious-metal dealers, asset managers and similar are not deposits if settled within 60 days.2119
Swiss SRO membership or a FINMA licence, which does your crypto model need?
Taking public deposits or designated crypto-based assets triggers BankA Art. 1a/1b, while SRO membership covers AML intermediation, which is non-prudential. A 60-day omnibus settlement account exemption applies under BankO Art. 5 para. 3 let. c no. 1. A Swiss crypto licensing decision tree separates SRO brokerage, FinTech custody and full banking.221921
What changes with the 2026-27 Swiss financial market reform for SRO-affiliated crypto firms?
The Federal Council consultation opened on 22 October 2025 and proposes FinIA amendments to regulate payment and crypto institutions. According to analysis, the proposed Crypto Institution licence in FinIA would end pure-SRO oversight of crypto custody. Commentary also covers the new Swiss payment token framework and the creation of Crypto Institutions.232425
What it really takes
Who do you have to hire for a Swiss SRO-affiliated VASP, and where must they be based?
You need at least one Swiss-resident individual signatory under Code of Obligations Art. 718 para. 4. PolyReg requires the VASP contact-person role to be held by an operationally active, Swiss-resident board or management member (VR/GL). A full-time local AML compliance officer (GwG-Beauftragter) has a salary benchmark of CHF 120,000 to CHF 180,000 a year.26273
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | No statutory minimum capital for AMLA/GwG financial intermediaries affiliating with an SRO. Neither VQF's nor PolyReg's own admission criteria include a capital threshold: both instead condition membership on the good reputation of the persons responsible for business conduct and on having a working AML/CFT organisation. A capital requirement only arises if the business instead needs a FINMA licence (e.g. a banking licence, which requires CHF 10 million minimum capital).3 | |
| Ongoing own funds | No ongoing capital-adequacy or own-funds test applies to SRO-affiliated intermediaries; supervision is organisational and AML-focused (periodic SRO audits of due-diligence files, billed hourly) rather than prudential. A capital-adequacy regime only attaches if the firm separately holds a FINMA licence (bank, securities firm, fund manager).3 | |
| Who is assessed | The individuals responsible for the intermediary's business conduct (management/board) must have a good reputation; PolyReg additionally requires VASP members to name a Switzerland-resident, operationally active board member as contact person. Vetting is carried out by the SRO itself at admission and through periodic audits, not by FINMA directly, unless the business also separately holds a FINMA licence.3 | |
| Substance and people | ||
| AML/CFT | Good reputation of the persons responsible for ensuring proper business conduct, and a functioning internal organisation able to meet AMLA due-diligence duties (customer identification, beneficial-owner checks, transaction monitoring, staff training); no industry experience requirement is imposed.3 | |
| Audit | For Virtual Asset Service Provider members specifically, PolyReg requires a mandatory in-person pre-admission audit at additional cost and a Switzerland-based, operationally active board member to act as the designated contact person; no postponement of that audit is granted because of crypto's elevated risk classification.3 | |
| Conditions to keep the licence | ||
| Requirement | A crypto business needs a full FINMA licence (typically a banking licence) instead of mere SRO affiliation once it holds clients' crypto-assets in a way that does not let each holding be attributed to an individual customer at all times: i.e. pooled/collective custody that creates a repayment claim against the firm: or otherwise accepts public deposits. FINMA states no banking licence is required only where the virtual currencies are stored separately on the blockchain for each customer.6 | |
| Requirement | The intermediary must remain affiliated with a FINMA-recognised SRO for as long as it carries on the activity; FINMA's public SRO Member Search lets counterparties verify that an affiliation is currently active.5 | |
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | Federal Act of 10 October 1997 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA) | Defines non-bank parabanking financial intermediaries and VASPs (Art. 2 para. 3), mandates affiliation with a FINMA-recognised SRO (Art. 14 para. 1), establishes core due-diligence duties (Art. 3-8), MROS reporting (Art. 9), SRO recognition (Art. 24-28), and criminal sanctions (Art. 37-38). |
| 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, oversight over SROs, administrative enforcement powers, and criminal sanctions for unauthorised financial intermediation without SRO affiliation (Art. 44). |
| Act | Swiss Civil Code of 10 December 1907 (ZGB, SR 210) | Provides the private-law association foundation (Art. 60-79 ZGB) under which FINMA-recognised SROs are incorporated, govern member affiliation (Art. 70), and exercise internal disciplinary authority. |
| Secondary legislation | Ordinance of 11 November 2015 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Ordinance, AMLO, SR 955.01) | Defines quantitative thresholds for commercial activity (Gewerbsmässigkeit, Art. 7) that trigger mandatory SRO affiliation under AMLA Art. 2 para. 3, and details federal due diligence standards. |
| Regulator rules | 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 the baseline AML due-diligence standard that SRO regulations must meet or exceed, and establishes Travel Rule requirements for virtual asset transfers (Art. 10). |
| Regulator rules | VQF Regulations for Self-Regulation under AMLA (VQF SRO-Reglement, Dok. 400.1.2) | FINMA-approved binding regulation detailing admission requirements, due diligence obligations, AML compliance organisation, supervisory audits, and sanctions for VQF members. |
| Regulator rules | PolyReg SRO-Reglement and Statutes | FINMA-approved binding rules governing member admission, ongoing AML compliance, and mandatory pre-admission on-site audits specifically prescribed for Virtual Asset Service Provider (VASP) members. |
| Procedure law | Federal Act of 20 December 1968 on Administrative Procedure (Administrative Procedure Act, APA / VwVG, SR 172.021) | Governs administrative procedural standards, right to be heard, official languages, and delay appeals (Art. 46a), applied to SRO admission and exclusion rulings pursuant to BVGE 2023 IV/4. |
| 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 judicial appellate forum for challenges against SRO admission refusals and exclusions (Art. 31, Art. 33 let. h; BVGE 2023 IV/4). |
| Fee schedule | SRO Fee Regulations Suite (VQF Gebührenreglement Dok. 1101.5; PolyReg Beitrags- und Gebührenordnung) | Prescribes binding admission fees (CHF 1,200 to 2,000), recurring annual membership contributions, audit fees, training costs, and disciplinary fine scales. |
| Forms | SRO Admission Forms and Declarations Suite (VQF Dok. 801.2, 801.3, 807.1, 906.1, 907.1; PolyReg Aufnahmeantrag) | Mandatory questionnaires, fit & proper declarations, ownership disclosures, AML directives templates, and beneficial owner forms (Form A / K) required for SRO admission. |
5 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | FINMA Guidance 08/2019 'Payment transactions on the blockchain' (Travel Rule) | Specifies supervisory expectations applying AMLO-FINMA Art. 10 (Travel Rule) to crypto transfers, mandating transmission and verification of originator/beneficiary customer data. |
| Related regime | Federal Act of 8 November 1934 on Banks and Savings Banks (Banking Act, BankA) | Demarcates the regulatory boundary where crypto custody or deposit taking crosses from mere SRO affiliation into banking or FinTech licence requirements (Art. 1a, 1b). |
| Related regime | Federal Act of 15 June 2018 on Financial Institutions (Financial Institutions Act, FinIA) | Delineates asset manager and trustee licensing from parabanking financial intermediation, and abolished direct FINMA AML licensing (DUFI) in favor of mandatory SRO affiliation. |
| 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) | Integrated ledger-based securities into Swiss Code of Obligations (Art. 973d ff. OR), clarified crypto-asset segregation upon bankruptcy in Debt Enforcement Act (SchKG Art. 242a), and updated AMLA provisions. |
| Related regime | Swiss Criminal Code of 21 December 1937 (SCC / StGB, SR 311.0) | Defines the criminal predicate offenses of money laundering (Art. 305bis) and lack of due diligence in financial operations (Art. 305ter) enforceable against financial intermediary executives. |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | VQF's FAQ only says an application for admission must be submitted with all required documents, and that applicability enquiries may be sent by email to info@vqf.ch or via the contact form. Art. 14 para. 1 AMLA is cited as the basis for the affiliation requirement, not for a submission method.481 | Anti-Money Laundering Act (AMLA / GwG, SR 955.0) Art. 14 para. 1 |
| Language | The only rule stated covers documentation kept in the AMLA file: documents of fundamental significance for establishing facts about an AMLA-relevant business relationship that are not written in a Swiss official language or in English must be translated into English or a Swiss official language by an appropriately qualified and approved translator.439 | |
| What the application contains | For VQF, admission requirements and procedure are set by the SRO Regulations (Doc. 400.1.2), whose Arts. 3 and 4 apply to applicants, and by the admission guidelines: Doc. 801.2 for natural persons and 801.3 for legal entities. Application forms are 901.3 (natural persons) and 901.1 (legal entities), plus 901.2 (description of business activities). The required set depends on the applicant's legal form.10894 | Anti-Money Laundering Act (AMLA / GwG, SR 955.0) Art. 14 para. 2; SRO Regulations approved by FINMA pursuant to AMLA Art. 24-25 (e.g. VQF SRO-Reglement Dok. 400.1.2 Art. 4-6; PolyReg SRO-Reglement Art. 5-7); SRO Admission Guidelines (VQF Wegleitung Dok. 801.2 / 801.3; PolyReg Aufnahmeantrag) |
| Decision clock | VQF states no binding decision timeframe in weeks: processing duration depends on whether the application is complete and correct and on the scope and complexity of the documents. Review begins only once the processing fee (plus VAT) is received and all forms are fully completed, signed and supported; follow-up questions and document requests cause delays. No deadline, clock-stop, extension or silence rule is stated.4 | |
| Fees set by law | Fees are set by each SRO's Fee Regulations. VQF's Fee Regulations govern admission fees, annual membership contributions and other costs, including a minimum annual fee; training course fees are also set there. Reported VQF figures include an admission processing fee around CHF 2,000, an admission audit of CHF 750-3,000 and an annual base membership fee around CHF 400. PolyReg's reported figures include an admission fee around CHF 1,600 and a CHF 250 hourly audit rate.103411 | SRO Fee Regulations approved under AMLA Art. 24-25: VQF Gebührenreglement (Dok. 1101.5, effective 1 Jan 2026); PolyReg Beitrags- und Gebührenordnung |
| Grounds for refusal | VQF's FAQ gives the main admission requirements: activities within the scope of the AMLA (Art. 2 para. 3 et seq.), compliance with the applicable anti-money-laundering requirements, a good reputation of the persons responsible for proper business conduct, and willingness to cooperate with VQF's supervisory activities. Active membership is unavailable without corresponding financial intermediary or advisor activity. The VQF board decides admission, often conditionally.12413 | |
| Appeal | They describe VQF internal arbitration for sanction decisions (Art. 27 VQF by-laws and arbitration regulations, VQF Doc. 608.01) and company-law arbitration clauses, but state no appeal body, court, deadline or legal basis for appealing a refusal of admission.14159 | Federal Administrative Court Act (FACCA / VGG, SR 173.32) Art. 31, Art. 33 let. h; Administrative Procedure Act (APA / VwVG, SR 172.021) Art. 5 para. 1, Art. 44, Art. 50 para. 1; landmark precedent BVGE 2023 IV/4 (B-2149/2022). An SRO decision rejecting an admission application under AMLA Art. 14 constitutes an appealable administrative ruling (Verfügung) under public federal administrative law. A subsequent appeal on questions of federal law lies to the Swiss Federal Supreme Court (Bundesgericht) pursuant to Art. 82 let. a of the Federal Supreme Court Act (FSCA / BGG, SR 173.110) within 30 days. For internal associative disputes, SRO regulations may additionally provide an internal arbitration forum (e.g. VQF Schiedsreglement Dok. 608.01; Swiss Civil Code Art. 75). |
| Validity | None of the governing texts held for this licence (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 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); 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); Ordinance on Banks and Savings Banks (Banking Ordinance, BankO); Ordinance on Banks and Savings Banks (Banking Ordinance, BankO); 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); Anti-Money Laundering Ordinance / FINMA-Money Laundering Ordinance (AMLO)) contains a provision on a fixed term or expiry of the licence.16 | |
| Change of control | Any change of control triggers an SRO review. If new owners or governance fail fit-and-proper checks, membership can be revoked despite the purchase.1011 | |
| Reapplying after a refusal | None of the governing texts held for this licence (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 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); 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); Ordinance on Banks and Savings Banks (Banking Ordinance, BankO); Ordinance on Banks and Savings Banks (Banking Ordinance, BankO); 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); Anti-Money Laundering Ordinance / FINMA-Money Laundering Ordinance (AMLO)) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | SRO membership does not allow passporting into the EU: Switzerland is outside the EEA, so a Swiss entity cannot MiCA-passport into the EU. EU retail business usually requires an EU CASP setup, and reverse solicitation is narrowing. The Banking Ordinance (Arts. 18-20) contains cross-border rules for banks and persons under Art. 1b BankG, including a duty to notify FINMA before starting activity abroad, but these do not address SRO-affiliated VASPs.11117 |
How long it takes
How long does Swiss SRO affiliation really take?
In practice, admission to a crypto SRO (VQF) takes three to six months from the initial application. PolyReg adds a mandatory in-person VASP supervisory interview, which creates multiple review cycles. There is no statutory processing deadline, and VQF declines to give a binding timeframe in weeks.1334
What it costs
What does a Swiss SRO affiliation cost in total, first year and ongoing?
Costs depend on the SRO. PolyReg's tariff sets admission at CHF 1,600, annual membership at CHF 1,400 to 5,800, audit at CHF 250 per hour and training at CHF 600/400. VQF Fee Regulations 1101.5 (effective 1.1.2026) set admission at CHF 2,000, vetting at CHF 300 to 6,000 and an annual fee floor of CHF 1,250. Ombudsman affiliation is required; FINOS charges CHF 460 in 2026.282930
Approval odds and who can own it
What are the real approval odds for a Swiss SRO affiliation, and why do applications fail?
SROs conduct periodic audits and impose sanctions ranging from warnings and fines to expulsion. SRO membership gives no client asset or solvency protection: Lykke was allegedly hacked in June 2024 (US$22.8M stolen) and Lykke Corp UK was wound up in the UK. FINMA has shut down unapproved crypto operations under banking law, for example Envion AG, which raised CHF 90M+ and entered bankruptcy liquidation.313233
After you get the licence
Will you get a bank account and payment processing with a Swiss SRO affiliation?
Swiss banks have debanked crypto startups and terminated their accounts, including a Lugano mining firm holding CHF 130,000 in ASIC machinery. A compilation lists 19 Swiss banks that offer accounts or crypto services to companies, including Sygnum, AMINA, Hypothekarbank Lenzburg and Maerki Baumann.3435
Yes. A refusal can be challenged as an association resolution under Swiss Civil Code Art. 75, within one month of learning of it. Eligible intermediaries also have a statutory entitlement to SRO admission under AMLA Art. 14 para. 2. SRO arbitration follows ZPO Part 3, and Federal Supreme Court appeals against arbitral awards run under ZPO Art. 389 with restricted grounds.362837
Membership runs indefinitely as long as you comply continuously with the SRO regulations. Under VQF SRO Regulations Art. 6(2), you must inform SRO VQF without undue delay of changes to material personnel or structural facts and seek approval; a qualified stake is 10% or more direct or over 50% indirect. SROs also require notification of changes in executive management, the compliance officer and operations.4
What happens at the VQF audit three months after joining?
An early compliance audit applies after admission. If an officer is found not competent, the affiliation can be revoked. SROs also run periodic audits and can impose sanctions from warnings and fines to expulsion. VQF Fee Regulations 1101.5 charge a flat CHF 750 to administer and approve the audit report, plus an admission audit fee based on expenditure.2131
Buying a company that already holds it
SRO membership belongs to the affiliated legal entity itself and is not a separately transferable licence: it lapses if the entity is dissolved or leaves the SRO. A new controlling owner is vetted under the SRO's own admission criteria (good reputation, AML organisation) rather than through a FINMA process, unless the business also separately holds a FINMA licence, in which case FINMA's own change-of-control approval applies as well.1
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.7
Ready-made companies holding this licence: see verified positions.
VASP in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Abu Dhabi Global Market (ADGM) | VASP licenceFinancial Services Permission with Virtual Asset Activities Endorsement | FSRA | USD 250,000 | USD 20,000 | n/a |
| Australia | VASP licenceRegistration as a virtual asset service provider (VASP) on the AUSTRAC Virtual Asset Service Provider Register (formerly the Digital Currency Exchange Register) | AUSTRAC | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class F (Full) Licence | BMA | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class M (Modified) Licence | BMA | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class T (Test) Licence | BMA | n/a | n/a | n/a |
| British Virgin Islands | Virtual Assets Service Provider Registration | BVI FSC | n/a | n/a | n/a |
| Cayman Islands | Virtual Asset Service Provider Licence | CIMA | n/a | KYD 5,000 | n/a |
| Cayman Islands | Virtual Asset Service Provider Registration | CIMA | n/a | KYD 1,000 | n/a |
| Dubai (VARA) | Virtual Asset Advisory Services Licence | VARA | AED 100,000 | AED 40,000 | n/a |
| Dubai (VARA) | Virtual Asset Broker-Dealer Services Licence | VARA | AED 600,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Custody Services Licence | VARA | AED 600,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Exchange Services Licence | VARA | AED 1,500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Lending and Borrowing Services Licence | VARA | AED 500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Management and Investment Services Licence | VARA | AED 500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Transfer and Settlement Services Licence | VARA | AED 500,000 | AED 40,000 | n/a |
| Dubai International Financial Centre (DIFC) | Financial Services Permission with Crypto Token Activities Endorsement | DFSA | USD 1,000,000 | USD 15,000 | n/a |
| El Salvador | Proveedor de Servicios de Activos Digitales (PSAD) registration | CNAD | USD 2,000 | USD 5,475 | ~0.9 mo |
| Germany | Qualified crypto custody licence | BaFin | n/a | n/a | n/a |
| Ireland | Virtual Asset Service Provider AML/CFT Registration | CBI | n/a | n/a | n/a |
| Mauritius | Virtual Asset Advisory Services (Class I) | FSC | n/a | n/a | n/a |
| Mauritius | Virtual Asset Broker-Dealer (Class M) | FSC | n/a | MUR 2,000,000 | n/a |
| Mauritius | Virtual Asset Wallet Services (Class O) | FSC | n/a | n/a | n/a |
| Mauritius | Virtual Asset Custodian (Class R) | FSC | n/a | MUR 5,000,000 | n/a |
| Mauritius | Virtual Asset Market Place (Class S) | FSC | n/a | MUR 6,500,000 | n/a |
| Seychelles | Virtual Asset Service Provider Licence / RegistrationVirtual Asset Service Provider Licence / Registration (Wallet Provider, Exchange, Broking, Investment Provider) under the Virtual Asset Service Providers Act 2024 | FSA | n/a | SCR 75,000 | n/a |
| South Africa | Crypto Asset Service Provider licenceCrypto Asset Service Provider licence (an FSP authorisation category under FAIS, not a MiCA-equivalent regime) | FSCA | n/a | n/a | n/a |
| Switzerland | Financial intermediary / VASP SRO affiliation | FINMA | CHF 10,000,000 | CHF 1,600 | n/a |
| United Kingdom | Cryptoasset Business Registration (MLRs 2017) | FCA | n/a | GBP 11,260 | ~3 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
Getting this licence
Protegra handles this licence end to end: crypto licensing in Switzerland: process, timeline and our fee.
Frequently asked questions
What is a Swiss VASP SRO affiliation and do you actually need one?
Yes, if you act as a financial intermediary. SRO affiliation is a statutory AML registration, not a banking licence. Under AMLA Art. 2 para. 3, financial intermediaries must affiliate with a recognised SRO (Art. 14 para. 1). Direct FINMA AML supervision (DUFI) was abolished on 1 January 2020, so non-bank intermediaries are channelled to SROs. No banking licence is needed if virtual currencies are stored separately per customer and attributable at all times; such custody is AMLA-regulated.
How long does Swiss SRO affiliation really take?
In practice, admission to a crypto SRO (VQF) takes three to six months from the initial application.
What does a Swiss SRO affiliation cost in total, first year and ongoing?
Costs depend on the SRO. PolyReg's tariff sets admission at CHF 1,600, annual membership at CHF 1,400 to 5,800, audit at CHF 250 per hour and training at CHF 600/400. VQF Fee Regulations 1101.5 (effective 1.1.2026) set admission at CHF 2,000, vetting at CHF 300 to 6,000 and an annual fee floor of CHF 1,250. Ombudsman affiliation is required; FINOS charges CHF 460 in 2026.
What are the real approval odds for a Swiss SRO affiliation, and why do applications fail?
SROs conduct periodic audits and impose sanctions ranging from warnings and fines to expulsion.
What does a Swiss VASP SRO affiliation let you do, and where can you serve clients?
SRO affiliation covers financial intermediation activities, including virtual currency transmission, under AMLA Art. 2 para. 3 and AMLO Art. 4.
Will you get a bank account and payment processing with a Swiss SRO affiliation?
Swiss banks have debanked crypto startups and terminated their accounts, including a Lugano mining firm holding CHF 130,000 in ASIC machinery.
Who do you have to hire for a Swiss SRO-affiliated VASP, and where must they be based?
You need at least one Swiss-resident individual signatory under Code of Obligations Art. 718 para. 4.
Is a Swiss SRO affiliation right for your model, and what are the alternatives?
A Swiss crypto licensing decision tree separates SRO brokerage, FinTech custody and full banking.
Swiss SRO membership or a FINMA licence, which does your crypto model need?
Taking public deposits or designated crypto-based assets triggers BankA Art. 1a/1b, while SRO membership covers AML intermediation, which is non-prudential.
What changes with the 2026-27 Swiss financial market reform for SRO-affiliated crypto firms?
The Federal Council consultation opened on 22 October 2025 and proposes FinIA amendments to regulate payment and crypto institutions.
Sources
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