SRO Membership · Switzerland

Swiss Crypto License:
The Right License May Not Be a License

Most crypto businesses seeking a crypto license in Switzerland do not need a banking authorisation. But that does not mean they can treat regulation as an incorporation exercise.

Calculate your Switzerland setup cost Talk to a Swiss crypto licensing expert
In short

How do you get a crypto exchange license in Switzerland?

For most crypto exchanges, OTC desks and payment processors, a crypto exchange license in Switzerland means membership in one of the FINMA-recognised Self-Regulatory Organisations (SROs), such as VQF or PolyReg, under the Swiss Anti-Money Laundering Act, rather than a FINMA licence. The company is a Swiss GmbH with CHF 20,000 (€21,200) of paid-up capital or an AG with CHF 100,000 (€106,000). It needs a Swiss-resident AML Officer or an accepted external arrangement, a recognised external AML auditor and an AML/CFT policy suite that applies the Travel Rule from CHF 1,000 (€1,060). The SRO application fee starts at CHF 1,600 (PolyReg) or CHF 2,000 plus review charges (VQF). There is no statutory deadline: a well-prepared file takes about two to five months. Limited public deposits below CHF 100 million can call for a FINMA FinTech licence with CHF 300,000 (€318,000) minimum capital. SRO membership carries no EU passport. Protegra takes you from company formation to standing SRO membership, from CHF 28,000.

ItemFigureBasis
Supervisory routeMembership in a FINMA-recognised SRO, such as VQF or PolyRegSwiss Anti-Money Laundering Act
Company capitalCHF 20,000 (GmbH) / CHF 100,000 (AG, at least CHF 50,000 paid in)Swiss company law; paid into the company, not a fee
SRO application feeFrom CHF 1,600 (PolyReg) or CHF 2,000 plus review charges (VQF)SRO fee schedules
Time to admissionAbout 2–5 monthsNo statutory deadline; depends on the SRO and the AML file
FinTech licenceCHF 300,000 minimum capital; public deposits below CHF 100 millionFINMA
Banking licenceCHF 10 million minimum capital, fully paidFINMA
EU passportNot includedSRO membership is an AML-supervision route, not a CASP authorisation

Sources: Swiss Anti-Money Laundering Act (AMLA); FINMA; PolyReg and VQF fee schedules; Swiss Code of Obligations (GmbH and AG capital).

Why teams choose Protegra

Built for Crypto — Not Adapted to It

Swiss SRO membership is often described as “light touch.” That creates the wrong expectation. The route may be lighter than a banking licence, but the SRO still needs to understand your transaction flows, source-of-funds controls, wallet architecture, client onboarding, AML accountability, and Travel Rule process. A generic policy pack is not enough.

100% crypto-focused.

We build Swiss SRO membership as an operating framework — not a one-time filing.

Start your application

The right route first

before the company is built around the wrong one. We assess whether the proposed model genuinely fits SRO membership or whether deposit-taking, custody, lending, or trading activity points to a FinTech or banking licence instead.

We choose the SRO around the model

VQF, PolyReg, and other FINMA-recognised SROs do not assess every model in the same way. We identify the SRO that fits the business activity, custody structure, fiat exposure, governance model, and compliance requirements—rather than selecting based on name recognition alone.

We build AML around actual transaction flows

The AML programme must reflect how customers onboard, how fiat and crypto move, how wallets are controlled, which providers are outsourced, and where financial-crime risk appears in the user journey. We build the policy suite, control framework, risk assessment, and operational processes around your actual product.

We make the Travel Rule operational

Travel Rule compliance cannot remain a paragraph in an AML policy. Identity verification thresholds, linked transactions, wallet information, beneficiary data, and transaction monitoring must work in production. We turn Swiss requirements—including the CHF 1,000 (€1,060) identification threshold and related-transaction assessment—into practical controls that the operations and product teams can maintain.

We prepare for life after admission

SRO membership begins an ongoing compliance relationship. AML monitoring, annual external audit, policy updates, and evolving FINMA guidance need to be managed as the business scales.

SRO, not FINMA.
For most models.

SWISS SRO MEMBERSHIP

What Is a Crypto License in Switzerland: SRO Membership or FINMA?

11.7%
Effective corporate tax in Zug

Combined federal, cantonal, and municipal profit tax in Zug can be approximately 11.7%, subject to the company’s circumstances and applicable local tax treatment.

2–5
Months · Indicative SRO admission timeline

There is no fixed statutory deadline for SRO admission. Well-prepared applications can typically be completed within approximately two to five months, depending on the chosen SRO and the quality of the AML documentation.

10
FINMA-recognised SROs

Most qualifying crypto businesses meet their AML-supervision obligations through membership in one of Switzerland’s FINMA-recognised Self-Regulatory Organisations.

Supervisory route
Membership in a FINMA-recognised Self-Regulatory Organisation under the Swiss Anti-Money Laundering Act
Common SROs for crypto
VQF and PolyReg are established options; the appropriate choice depends on the activity and operating model
Company vehicle
Swiss GmbH or AG
AML responsibility
A Swiss-resident AML Officer, or an accepted external arrangement with a Swiss-resident deputy
External oversight
A recognised external AML auditor and a documented AML/CFT policy suite
EU passporting
Not included. Swiss SRO membership is an AML-supervision route, not a MiCA CASP authorisation or EU passport

The real decision is whether your custody model, deposit volumes, transaction flows, and client proposition fit the Swiss SRO route—or already require a FINMA FinTech or banking licence. Get that decision wrong, and you can spend months building governance for a tier that does not cover the business you intend to launch.

For the right model, membership in a FINMA-recognised Self-Regulatory Organisation gives you a defined AML-supervision route without taking on bank-level regulation from day one.

WHY SWITZERLAND

The Proof Is Not a Promise—It Is Already Operating

Switzerland does not ask a crypto business to rely on an untested regulatory story. The banks, protocols, specialist providers, and legal framework behind the market already exist.

Banking

The banks that proved the model works
  • Sygnum and AMINA Bank both hold full FINMA banking licences.
  • They demonstrate that Swiss regulation can accommodate crypto custody, trading, deposits, and institutional-grade digital-asset businesses.
  • Crypto-focused banking relationships already exist within the Swiss market, rather than needing to be invented after authorisation.
  • The goal is not merely SRO admission—it is a structure that can be understood by the bank you need to work with.

Ecosystem

Crypto Valley is an operating market
  • Switzerland’s Crypto Valley, centred on Zug, is one of the world’s most established blockchain clusters.
  • The region is home to a dense network of blockchain companies, specialist legal advisers, AML providers, auditors, banks, and technology teams.
  • Major blockchain organisations including the Ethereum Foundation, Cardano’s IOHK, and Dfinity have established a presence in and around Zug.
  • This is not a jurisdiction trying to attract crypto through marketing alone. It is a market with years of operating history.

Proportionality

Regulation that follows the activity
  • Swiss regulation distinguishes between qualifying AML-supervised crypto activities and business models that require a FinTech or banking licence.
  • Certain custody models may not trigger the same prudential threshold as collective custody, depending on how client assets are held and controlled.
  • This allows qualifying businesses to build a supervised AML structure without automatically carrying the CHF 300,000 (€318,000) minimum-capital requirement associated with the FinTech licence.
  • The key is to classify the actual custody, deposit, transaction, and client-asset model correctly before incorporation.
Start your Switzerland application

Zug.
Your Swiss base.

CHOOSE YOUR SWISS REGULATORY ROUTE

Which Swiss Regulatory Tier Do You Need: SRO Membership, FinTech License, or Bank?

Switzerland does not apply one “crypto licence” to every business. The regulatory burden depends on what you actually do with client assets, deposits, custody, and trading activity. Choosing the wrong route can mean building an unnecessary FINMA application—or joining an SRO structure that does not legally cover the business you plan to launch.

For exchange, OTC, payments, and qualifying custody modelsGmbH capital requirement · ≈€21,200From CHF 20,000

SRO Membership

SRO membership is generally the appropriate route for crypto exchanges, OTC desks, payment processors, and qualifying non-custodial or limited-custody models that fall within Swiss AML supervision but do not require a FINMA FinTech or banking licence.

A Swiss GmbH requires CHF 20,000 (€21,200) in paid-up capital. An AG requires CHF 100,000 (€106,000) in share capital, of which at least CHF 50,000 (€53,000) must be paid in at incorporation.

Included

  • AML supervision under the Swiss Anti-Money Laundering Act
  • Membership in a FINMA-recognised Self-Regulatory Organisation
  • A defined AML/CFT, onboarding, monitoring, and audit framework
  • A route designed for qualifying crypto business models

Does not cover

  • Deposit-taking beyond the applicable threshold
  • Lending activities requiring higher-tier authorisation
  • Collective custody at scale
  • A multilateral DLT trading venue
Calculate cost ⟶Apply ⟶
For limited deposit-taking businessesMinimum capital requirement · ≈€318,000From CHF 300,000

FINMA FinTech Licence

A FINMA FinTech licence may be appropriate if the business takes public deposits while remaining below the CHF 100 million (€106 million) threshold and does not invest those deposits or pay interest on them.

It provides a higher regulatory tier than SRO membership without becoming a full banking licence.

Included

  • The AML and governance framework required for a more substantial regulated business
  • Limited deposit-taking within the applicable CHF 100 million (€106 million) cap
  • A route for models that exceed the scope of standard SRO membership

Does not cover

  • Deposit-taking above the relevant cap
  • Unrestricted collective custody
  • Full banking activity
Calculate cost ⟶Apply ⟶
For custody at scale, major deposit-taking, and market infrastructureBank minimum capital, fully paid · ≈€10.6 millionCHF 10 million

Banking Licence / DLT Trading Facility

This is the highest Swiss regulatory tier. It applies to businesses that take deposits above the FinTech threshold, operate collective custody at scale, or run a multilateral DLT trading venue, which is a separate FINMA authorisation with its own capital rules.

It requires a more substantial Swiss governance and prudential structure, including a Swiss head office, registered office, and a board of at least three members, at least a third of them independent.

Included

  • Full banking activities, subject to the licence scope
  • Large-scale custody and deposit-taking
  • Multilateral trading of qualifying DLT securities
  • Direct prudential supervision by FINMA

Requires

  • A full FINMA authorisation process
  • Bank-level capital, governance, risk, and organisational arrangements
  • A significant Swiss operating presence
Calculate cost ⟶Apply ⟶
COST OVERVIEW

How Much Does SRO Membership in Switzerland Cost?

A realistic view of the spend from Swiss company formation to standing SRO membership. The final amount depends on the company form, the chosen SRO, the custody and transaction model, the AML Officer arrangement, audit scope, and banking requirements.

Three levels of support

How much of the work do you want us to do?

01 · TEMPLATES

You get the documents. You file them yourself.

CHF 14,000
  • The full policy, procedure and governance pack for this regulator
  • Application forms filled in as far as your own data allows
  • One handover session so you know what goes where
  • You deal with the regulator yourself
02 · TAILORED

We write the file around your business.

CHF 28,000
  • Everything above, rewritten around your actual model
  • Business plan, governance and AML/CFT built from your data
  • We assemble and check the whole file before it goes in
  • You submit and answer; we stay on call throughout
Every figure on this page assumes this level
03 · DECISION

We carry the file to the regulator’s answer.

CHF 56,000
  • Everything above, and we file it
  • Every regulator question and clarification round comes to us
  • Meetings and pre-application engagement handled for you
  • We stay on the file until the decision is issued

One licence, three levels — the regulator asks for exactly the same file in all three, and what changes is how much of it sits with you. The middle level is the default here: every price on this page is quoted at it, and the selector above the total switches between them.

Moving up or down changes our fee and nothing else — not the capital, not the state fees, not the statutory clock. Carrying a file to the decision is not a promise of approval: no adviser can give one, and an adviser who does is selling you something other than advice.

Protegra legal feesRegulatory-tier analysis, SRO selection, membership application, documentation, and management of the review.CHF 28,000
Swiss GmbH formation and baseline corporate setupIncorporation, notarisation, commercial-register entry, and tax analysis.CHF 4,500
Swiss AG formation and baseline corporate setupIncorporation, notarisation, commercial-register entry, and tax analysis.CHF 5,500
Minimum paid-up capital — GmbHCompany capital is not a fee. It is paid into the company Approximately €21,200.CHF 20,000
Minimum paid-up capital — AGCompany capital is not a fee. It is paid into the company Approximately €106,000.CHF 100,000
Annual SRO membership feeper year, recurring after admission.CHF 2,500
Swiss-resident AML Officer / external arrangementper month — CHF 54,000 annualised.CHF 4,500 / mo
Annual external AML auditper yearCHF 9,000
Accounting and financial administrationper month — CHF 6,000 annualised.CHF 500 / mo
Fixed charges — paid to the SRO and the commercial register.
SRO application feefrom CHF 1,600 (PolyReg) or CHF 2,000 plus review charges (VQF)
Company capital is not a feeCHF 20,000 GmbH / CHF 100,000 AG, paid into the company
ROADMAP WITH PROTEGRA

How Long Does SRO Membership in Switzerland Take, Month by Month?

A Swiss SRO project is structured in the order that matters: the right regulatory tier first, then the company, AML accountability, SRO filing, banking readiness, and day-one operating controls.

We assess the business against the Swiss regulatory perimeter:

  • Proposed crypto-asset services
  • Client-asset custody model
  • Deposit-taking activity
  • Whether public deposits may approach or exceed CHF 100 million (€106 million)
  • Fiat-payment flows
  • Lending activity, if any
  • Transaction volume and customer profile
  • Whether SRO membership, a FinTech licence, or a banking licence is required
  • We then identify the appropriate SRO—VQF, PolyReg, or another FINMA-recognised body—based on the actual model

The Swiss GmbH or AG is incorporated. The capital is paid up, the registered office is secured, and the governance model is put in place.

This includes the AML Officer, Swiss-resident deputy or accepted alternative arrangement, board responsibilities, beneficial ownership documentation, and required external auditor.

We develop the AML/CFT framework around the transaction flow and operating model:

  • Customer onboarding and identification
  • KYC and source-of-funds procedures
  • Risk assessment and customer-risk classification
  • Sanctions and PEP screening
  • Transaction monitoring and escalation
  • Wallet and blockchain-risk controls
  • Travel Rule processes
  • Outsourcing and provider oversight
  • Record keeping and audit trails

The complete SRO membership file is submitted with the company structure, governance information, beneficial ownership, financial information, AML documentation, and personal documents for directors and qualified shareholders.

We manage clarification requests and document updates to keep the review moving.

Once membership is granted, the company moves into its supervised operating setup:

  • Banking and payment-provider relationships are activated
  • AML monitoring and escalation processes go live
  • Travel Rule controls are operationalised
  • The audit relationship and compliance calendar are established
  • The team is prepared for day-one AML accountability
06

Post-Admission Support

INCLUDED, NOT OPTIONAL

SRO admission is the beginning of the AML-supervision relationship. We remain involved as the company moves from filing to live operations.

Ongoing AML and sanctions monitoring

Support for transaction monitoring, customer risk reviews, escalations, policy updates, and financial-crime controls.

Annual external audit readiness

Preparation for the external AML audit, documentation management, remediation support, and follow-up actions.

FINMA and SRO guidance tracking

Review of relevant Swiss guidance, including developments affecting custody, AML controls, transaction monitoring, and operational risk.

Governance and compliance maintenance

Support for changes in activity, governance, control functions, outsourcing, client risk profile, and regulatory expectations.

Begin Step 1Talk to a Swiss crypto licensing expert
WHY PROTEGRA

Where Do Swiss SRO Applications Actually Stall?

Switzerland’s light-touch reputation can make founders underestimate what an SRO file needs to prove. The most expensive delays tend to happen before and after the application—not in the act of submitting it.

See how we work

“Which SRO actually understands our model?”

Not every SRO is the same fit for every activity. A crypto-native exchange, a hybrid fiat-and-crypto payment business, an OTC desk, and a wallet provider may require different expectations around governance, controls, and documentation.

⟶ We select the SRO based on the operating model—not the brand name.

“Is SRO membership enough for us?”

A business may begin as a qualifying SRO model and later discover that its custody setup, deposit volume, lending activity, or trading proposition needs a higher FINMA tier.

⟶ We test the regulatory perimeter before you build the company and AML structure around the wrong route.

“Who is actually responsible for AML?”

An AML Officer cannot be an empty job title. The person needs the right experience, availability, accountability, and local structure to meet the SRO’s expectations.

⟶ We help establish the AML Officer, deputy arrangement, responsibilities, policies, and external-auditor relationship before filing.

“Can we make the Travel Rule work in production?”

Swiss AML and Travel Rule obligations must translate into real customer and transaction controls. If onboarding, wallet data, linked transactions, and screening are not operationally connected, the compliance programme will fail under review.

⟶ We turn the regulatory requirement into workflows the team can use.

“Will a Swiss bank work with us?”

SRO membership only creates value if the business can operate. Banking partners still need to understand the governance, AML framework, transaction model, source-of-funds controls, and risk profile.

⟶ We build banking readiness into the project early, rather than waiting for SRO admission to start the conversation.

“We are admitted. What happens now?”

Admission leads directly into ongoing monitoring, annual audit, policy maintenance, and regulatory change management.

⟶ We remain involved after membership begins, so the compliance framework continues to work as the business grows.
Client experience

How These Problems Get Resolved

Selecting an SRO is not the same as confirming that SRO membership covers your business. Choose a challenge to see how a Swiss crypto project moves from an uncertain regulatory route to a structure ready for admission and operation.

Before Protegra
“We assumed SRO membership was the standard Swiss crypto route. But we had not tested whether our custody model, fiat flows, and client-asset structure could actually stay within that tier.”
With Protegra
“We mapped the activity before incorporating the company. We knew which regulatory route matched the model—and what would need to change if we wanted to remain within the SRO framework.”
FFounder, crypto-asset services firm, Switzerland
Talk to a Swiss crypto licensing expertSchedule a free call
FAQ

Swiss Crypto Licensing, Answered Honestly

About the Swiss regulatory route
01Is there really no single Swiss crypto licence?
Correct. Switzerland does not apply one bespoke “crypto licence” to every business. Many qualifying crypto businesses meet their AML-supervision obligations through membership in a FINMA-recognised SRO. However, the model may require a FINMA FinTech or banking licence if it involves activities such as significant deposit-taking, collective custody at scale, lending, or a multilateral trading venue.
02Which SRO should we choose?
The appropriate SRO depends on the proposed activity, custody model, fiat exposure, transaction flows, governance, AML structure, and business plan. VQF and PolyReg are established options, but the right fit must be assessed for the specific model.
03Is SRO membership enough for a crypto exchange?
It may be, depending on how the exchange operates. The assessment must consider whether the business takes deposits, controls client assets, provides collective custody, facilitates fiat flows, conducts lending, or operates a trading venue. If the model involves limited public deposits, the CHF 100 million (€106 million) FinTech threshold becomes relevant. The legal classification should be completed before the regulatory route is selected.
Banking, Travel Rule and EU scope
04Will a Swiss bank open an account for a crypto business?
Switzerland has crypto-focused banking infrastructure, including FINMA-licensed digital-asset banks. But banking remains dependent on the actual risk profile, governance, AML framework, source-of-funds controls, transaction model, and the bank’s onboarding decision.
05How strict is the Swiss Travel Rule?
The Travel Rule must be implemented in the company’s actual customer and transaction processes. Swiss requirements include identification obligations from the applicable CHF 1,000 (€1,060) threshold and aggregation of linked transactions over the relevant period. The exact operational approach should be designed around the business model and current legal requirements.
06Does Swiss SRO membership give us an EU passport?
No. SRO membership is a Swiss AML-supervision route. It does not provide a MiCA CASP authorisation or passporting rights into the EU. A business serving EU clients may need a separate MiCA analysis and, where required, an EU/EEA CASP authorisation.
Timeline and life after admission
07How long does SRO admission take?
There is no fixed statutory deadline. A well-prepared SRO membership project may take approximately two to five months, depending on the chosen SRO, the completeness of the entity and governance setup, AML documentation, key-person readiness, and any clarification requests.
08What happens after SRO membership is granted?
The business enters ongoing AML supervision. This includes transaction monitoring, risk reviews, policy maintenance, required reporting, annual external audit, and updates as the business model or regulatory expectations evolve.
Get a personalised Swiss planBook a call

Reference: the Financial intermediary / VASP SRO affiliation (Finanzintermediär nach Art. 2 Abs. 3 GwG / AMLA) in the Licensing Atlas.

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Leave your details and we will assess whether SRO membership is the right Swiss route for your crypto business. You will receive a personalised Switzerland regulatory plan within 24 hours.

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