How to Obtain a FINMA Licence: Banking, Securities Dealer, and Fintech Authorisation in Switzerland

Switzerland’s financial regulatory framework, administered by the Swiss Financial Market Supervisory Authority (FINMA), is one of the world’s most respected and commercially valuable. A FINMA licence signals to international counterparties, institutional clients, and correspondent banks that a firm meets exacting standards for governance, capital adequacy, risk management, and fit-and-proper conduct. In the digital asset space, FINMA’s 2019 banking licences for Sygnum and AMINA Bank became internationally recognised benchmarks for regulated crypto banking.

Understanding exactly what a FINMA licence requires — and how to obtain one — is essential for any institution seeking to operate in Swiss financial services. This guide covers the six primary FINMA licence categories, the step-by-step application process for the most commercially significant licences, capital requirements, timeline realities, and cost considerations.

For background on FINMA’s structure and supervisory powers, see our overview of FINMA as Switzerland’s integrated financial regulator.

The Six Primary FINMA Licence Categories

FINMA supervises and authorises entities across six primary regulatory categories, each governed by distinct statutory provisions:

1. Banking Licence (Banklizenz)

Governed by the Federal Banking Act (BankG), a banking licence authorises an institution to accept deposits from the public and to conduct banking business in Switzerland. It is the most comprehensive and most demanding of FINMA’s authorisation categories.

Who needs it: Any entity that accepts public deposits on a professional basis, or that holds itself out as a bank in Switzerland. This includes Swiss domestic banks, foreign bank branches, digital asset banks accepting customer deposits, and institutions accepting repayable funds from the public even if they do not call themselves banks.

Minimum capital: CHF 10 million in fully paid-up capital is the statutory minimum for most banking licence applications under the Banking Act. However, for systemically important institutions or those with significant trading or investment banking activities, FINMA’s own practice requires substantially higher capital — CHF 50-100 million+ for applicants with broad banking business models. Digital asset banks like Sygnum and AMINA launched with substantially more than the statutory minimum.

Prudential requirements: Once licensed, banks must comply with the capital adequacy framework derived from Basel III (implemented in Switzerland through FINMA Circular 2013/7 and successor instruments), liquidity coverage ratio and net stable funding ratio requirements, and the leverage ratio framework for larger institutions.

2. Securities Dealer Licence (Effektenhändlerlizenz)

The securities dealer licence, governed by the Financial Market Infrastructure Act (FinMIA) and the Financial Institutions Act (FinIA), authorises the professional trading in securities for own account or on behalf of clients, as well as market making, underwriting, and portfolio management activities involving securities.

Who needs it: Proprietary trading firms, broker-dealers, underwriting firms, and market makers operating in Swiss financial markets.

Minimum capital: CHF 1.5 million in paid-up capital for most securities dealer applicants. Systemically active dealers and those with significant market-making or underwriting activities will face higher capital expectations.

3. Fund Management Company Licence (Fondsleitungslizenz)

Authorises the establishment and management of Swiss collective investment schemes — including Swiss UCITS-equivalent funds and alternative investment funds — under the Collective Investment Schemes Act (CISA).

Who needs it: Asset managers establishing and operating FINMA-authorised investment funds in Switzerland. Distinct from the portfolio manager licence, which covers managers of third-party assets in individually managed accounts.

Minimum capital: CHF 1 million in paid-up capital (or higher depending on AUM managed).

4. Insurance Licence

Governed by the Insurance Supervision Act (VAG), authorising direct insurance and reinsurance activities in Switzerland.

5. Financial Market Infrastructure Licence

Covering stock exchanges, MTFs, OTFs, central counterparties, central securities depositories, and DLT Trading Facilities under the FinMIA. This is the licence category relevant to operators of digital asset exchanges and settlement platforms in Switzerland — including the new DLT Trading Facility licence, a world-first regulatory innovation enabling integrated trading, clearing, and settlement of ledger-based securities.

6. Fintech Licence (FinTech-Bewilligung)

The Fintech Licence, introduced into the Banking Act in 2019, is a lower-barrier authorisation specifically designed for firms that accept public deposits but do not provide credit (i.e., do not on-lend deposits). It represents Switzerland’s deliberate policy choice to create a regulatory on-ramp for payment service providers, digital asset custodians, and other deposit-accepting businesses that do not perform the credit transformation function of a full bank.

Maximum deposits: CHF 100 million.

Minimum capital: CHF 300,000.

Prohibition on interest payments and deposit on-lending: Fintech licence holders cannot pay interest on deposits or re-lend client funds.

Timeline: Typically 3-6 months — substantially faster than the banking licence process.

The Fintech Licence is frequently the appropriate first step for digital asset businesses, payment companies, or other financial technology firms that need to accept client funds but do not yet have the scale, capital, or operational infrastructure to support a full banking licence application.

The Banking Licence Application: Step-by-Step

For institutions pursuing a full Swiss banking licence — the most commercially significant and demanding authorisation — the following describes the end-to-end process.

Phase 1: Pre-Application Engagement

Before submitting a formal application, sophisticated applicants engage FINMA in pre-application discussions. FINMA offers preliminary discussions (Voranfragen) with prospective applicants to clarify regulatory expectations, discuss the appropriate licence category, and identify any structural issues that should be resolved before a formal application is submitted.

This phase is not formally required but is universally recommended by Swiss regulatory counsel. Pre-application discussions help applicants understand whether their proposed business model is viable under Swiss law, what capital level FINMA will practically expect (which often exceeds the statutory minimum), and what governance and organisational standards will be required.

Timeline: 1-3 months, depending on the complexity of the business model.

Phase 2: Preparation of Application Documentation

The formal banking licence application requires a comprehensive dossier. FINMA’s application requirements, set out in the Banking Act and the Banking Ordinance (BankV), include:

Business plan and description:

• Detailed description of the proposed banking activities
• Three-year financial projections (balance sheet, income statement, capital adequacy projections)
• Target market and client acquisition strategy
• Risk management framework and risk appetite statement
• Liquidity management framework

Organisational documentation:

• Articles of Association
• Organisational regulations (Organisationsreglement) — the governance charter specifying decision-making authorities, board and management responsibilities, and internal control architecture
• Descriptions of the three-line-of-defence risk and control model
• IT and operational infrastructure description, including outsourcing arrangements
• Business continuity and disaster recovery planning

Fit and Proper Materials:

• Curriculum vitae and detailed biographies for all proposed board members
• Curriculum vitae and biographies for all Executive Board members (CEO, CFO, CRO, CCO, Head of Internal Audit)
• Criminal record certificates for all board and senior management candidates
• References and professional background checks
• Declarations of business relationships and potential conflicts of interest

Capital and ownership documentation:

• Evidence of paid-up capital at or above the required minimum
• Full disclosure of beneficial ownership chain — FINMA requires complete transparency on all direct and indirect owners at the 10% threshold and above
• AML/KYC documentation on significant owners
• Funding source documentation

AML framework:

• Written AML and KYC policies and procedures
• Description of customer due diligence process
• Transaction monitoring framework
• PEP screening and sanctions compliance programme

Preparation timeline: 3-6 months for an experienced team with qualified legal and compliance counsel. Poorly prepared applications — incomplete documentation, inadequate fit-and-proper materials, unconvincing capital projections — will be returned or generate extended FINMA information requests that significantly delay the process.

Phase 3: Formal Submission and FINMA Review

The formal application is submitted to FINMA electronically. FINMA acknowledges receipt and assigns a case officer and project team. The review process involves:

Completeness review: FINMA checks that all required materials have been submitted. Incomplete applications trigger requests for supplementary documentation, each of which can add weeks to the timeline.

Substantive review of business plan: FINMA’s economists and supervisory specialists assess whether the proposed business model is viable, whether the financial projections are credible, and whether the proposed banking activities fall within the scope of the banking licence category.

Fit and Proper assessment: FINMA conducts its own background review of proposed board and senior management candidates. This includes checking external databases, consulting with other supervisory authorities (through IOSCO and bilateral supervisory cooperation agreements), and where warranted, interviewing candidates directly.

Organisational adequacy review: FINMA assesses whether the proposed governance structure, risk management framework, and internal control systems are appropriate for the size and complexity of the intended banking activities.

Capital adequacy review: FINMA reviews whether proposed capital is sufficient not just to meet the statutory minimum but to sustain the bank’s activities under stress scenarios and to fund operational build-out through to profitability.

Information requests: FINMA routinely issues formal requests for supplementary information (Auskunftsbegehren) during the review. Each request typically has a 30-60 day response window. Multiple rounds of information exchange are normal for complex applications.

Timeline for substantive review: 9-15 months for a banking licence. Simpler applications with clean ownership structures, experienced teams, and well-prepared documentation have been processed in under 12 months. Complex applications with novel business models, multi-jurisdictional ownership structures, or digital asset activities have taken 18+ months.

Phase 4: Approval, Conditions, and Licence Grant

If FINMA approves the application, it issues a licensing decision (Verfügung). Approvals are typically accompanied by conditions — operational milestones that must be met before business commencement, or ongoing conditions attached to the licence.

Common conditions include:

• Requirement to hire a specific additional senior officer (e.g., a Chief Risk Officer with specific qualifications) before commencement
• Requirement to complete a specific technology or systems build-out
• Requirement to engage an audit firm to conduct a licensing-ready review
• Operational commencement restrictions — FINMA may require that certain product categories are not offered until after an initial operating period

Annual supervisory audit: FINMA-licensed banks are required to appoint a FINMA-recognised audit firm to conduct the annual regulatory audit (prudenzieller Prüfer). The audit firm submits an annual report to FINMA covering compliance with regulatory requirements, internal control effectiveness, and any supervisory findings. Major audit firms active in Swiss banking regulatory audits include PwC, KPMG, Deloitte, and EY.

The Securities Dealer Licence: Process and Requirements

The securities dealer licence application follows a similar structure to the banking licence process but is generally faster — typically 6-12 months — and involves lower minimum capital (CHF 1.5 million statutory minimum).

Key requirements:

• Minimum two senior managers, both Swiss-resident or with demonstrated Swiss nexus
• Separate legal entity (AG or GmbH)
• Adequate organisational infrastructure for the trading activities proposed
• AML framework equivalent to banking requirements
• Fit-and-proper assessment of board and management

For firms entering Switzerland primarily to conduct securities dealing, market-making, or investment banking activities, the securities dealer licence is typically the appropriate entry licence — with a view to potentially upgrading to a banking licence as activities expand.

The Fintech Licence as Lower-Barrier Entry

For many digital asset businesses, payment companies, and financial technology firms, the FINMA Fintech Licence is the appropriate initial authorisation. Introduced in 2019 after a multi-year review process, it reflects FINMA’s recognition that accepting deposits does not automatically require the full capital and operational burden of a banking licence if the deposit-taking is ancillary to a non-lending business model.

Practical uses:

• Cryptocurrency exchanges accepting client fiat deposits pending conversion
• Payment service providers holding client funds in settlement float
• Digital asset custodians holding fiat and crypto assets for institutional clients

Limitations:

• CHF 100 million deposit cap — once approaching this threshold, a firm must either begin the banking licence process or restructure its deposit model
• Cannot pay interest on deposits
• Cannot lend deposited funds
• Restricted product range relative to a full bank

The Fintech Licence is often used as a bridge: firms obtain it to begin regulated operations in Switzerland while preparing the more extensive documentation, capital raise, and operational build-out required for a full banking licence application.

Fit-and-Proper Requirements in Detail

FINMA’s fit-and-proper assessment is rigorous and consequential. For board members and executive management of applicant banks, FINMA assesses:

Reputation: Absence of criminal convictions, regulatory sanctions, or material enforcement actions in any jurisdiction. FINMA checks international law enforcement and regulatory databases and communicates with peer supervisors through bilateral cooperation channels.

Expertise: Demonstrated competence in the relevant field. Board members supervising a digital asset bank are expected to have demonstrated understanding of digital asset technology, risks, and regulation — not just generic banking experience. Executive managers are expected to have substantial sector-specific experience.

Independence: Board members, and particularly the chair, are expected to be genuinely independent from significant shareholders. FINMA will assess whether proposed board members have the practical ability to exercise independent judgment when required.

Time commitment: Board members are expected to devote sufficient time to their supervisory responsibilities. Proposed chairs of Swiss banking boards who simultaneously hold multiple other board positions may face questions about time availability.

Swiss nexus: While FINMA does not formally require that board or management members be Swiss residents, having at least one or two senior managers based in Switzerland who can interact with FINMA, meet with supervisors, and oversee Swiss operations in person is practically important and expected.

Cost Considerations

Obtaining a FINMA banking licence involves substantial costs:

FINMA application fees: CHF 5,000-50,000+ in FINMA processing fees, depending on the complexity of the application.

Legal counsel: A lead Swiss regulatory law firm handling a banking licence application will typically charge CHF 200,000-500,000 in fees over the course of the application process, depending on complexity. Firms with complex ownership structures, novel business models, or digital asset activities should budget at the higher end.

Compliance and organisational consulting: Development of the AML framework, governance documentation, and operational procedures typically requires specialist compliance consulting: CHF 100,000-300,000.

Audit firm pre-engagement: Engaging the planned audit firm during the application process and obtaining their input on the control framework design is advisable and adds cost.

Total all-in costs for a banking licence application: CHF 500,000-1.5 million in professional fees, in addition to the capital required to be maintained in the entity at all times.

For the Fintech Licence, total professional fees are typically CHF 100,000-300,000, reflecting the simpler documentation requirements and faster process.

Timeline Summary

Frequently Asked Questions

What is the minimum capital required for a Swiss banking licence? The statutory minimum under the Banking Act is CHF 10 million in fully paid-up capital. However, FINMA’s practical expectations for applicants with broad banking business models typically run significantly higher — CHF 50-100 million or more — depending on the scale and nature of proposed activities. Digital asset banks have typically launched with substantially more than the statutory minimum.

How long does a FINMA banking licence application take? A well-prepared application with an experienced, clean team, straightforward ownership structure, and proven business model typically takes 12-15 months from formal submission to licence grant. Complex applications involving novel business models, digital assets, or multi-jurisdictional ownership structures routinely take 15-24 months. Pre-application engagement with FINMA can help avoid issues that would extend timelines once the formal process has begun.

Can a foreign company apply for a Swiss banking licence? A FINMA banking licence must be held by a Swiss legal entity — a company incorporated in Switzerland (AG or GmbH). Foreign banks seeking to operate in Switzerland typically establish a Swiss subsidiary or a Swiss branch. Branches of foreign banks require FINMA authorisation and are subject to Swiss prudential requirements, though with some structural differences from standalone Swiss banks.

What is the FINMA Fintech Licence and how does it differ from a banking licence? The Fintech Licence, introduced in 2019, authorises firms to accept public deposits up to CHF 100 million without lending those deposits or paying interest on them. The minimum capital is CHF 300,000, and the timeline is typically 3-6 months. It is appropriate for payment companies, digital asset custodians, and other fintech firms that need to hold client funds but do not perform the credit transformation function of a bank. Once a firm’s deposits approach the CHF 100 million cap, it must either begin the banking licence process or restructure operations.

Do I need Swiss legal counsel to apply for a FINMA licence? Strictly speaking, FINMA does not require that applicants engage Swiss legal counsel. In practice, essentially all successful applicants engage a Swiss regulatory law firm. FINMA’s requirements are detailed, the documentation expectations are precise, and an experienced Swiss regulatory lawyer who has previously guided successful applications can significantly improve both the quality of the application and the efficiency of FINMA’s review. Attempting a banking licence application without experienced Swiss regulatory counsel is a common and costly mistake.

Donovan Vanderbilt is a contributing editor at ZUG FINANCE. This article is informational and does not constitute legal, regulatory, or financial advice. Firms pursuing FINMA authorisation should engage qualified Swiss legal counsel.