Why Switzerland gets its own map
Switzerland builds its fintech and crypto regime outside MiCA — a deliberate strategy, not a lag. While the EU consolidated its market into the single CASP licence, the Swiss legislator wired tokens into existing law: a light deposit-taking licence in the Banking Act, securities that exist only on a blockchain register in the Code of Obligations, a new venue category in the Financial Market Infrastructure Act. The result is a ladder of five rungs, from self-regulatory organisation membership to a full banking licence.
This map answers two practical questions: where tokenised assets sit under familiar Swiss supervision and what happens to them if the provider fails — and which entry point to buy for which business, given that the 2028 reform will redraw the ladder's lower rungs.
The Article 1b fintech licence: a bank with two-thirds cut away
Since 2019, Article 1b of the Banking Act has allowed firms to accept public deposits of up to CHF 100 million without a full banking licence. The FINMA conditions are simple and strict: capital of 3% of deposits, at least CHF 300,000; paying interest is prohibited; investing client money is prohibited — the institution earns fees, not margin. The same licence covers collective custody of crypto assets. One restriction clients must be warned about before signing: deposits with a 1b institution are protected neither by the esisuisse scheme nor by depositor privilege — in bankruptcy they rank as ordinary creditor claims.
For comparison, a Luxembourg EMI requires €350,000 of capital and passports across 30 EEA countries; the Swiss 1b works only domestically, but lets a firm hold client balances at a scale e-money regimes cannot accommodate.
Who holds it — and who did not survive
According to the FINMA register as of August 2026, there are six holders: Audax Solutions AG (Zurich), Bivial AG (Zug), Relio AG (Zurich), Sequence SA (Geneva), SR Saphirstein AG (Zurich) and Yapeal AG (Zurich) — the regime's first licensee, live since 2020. Bivial is the former Klarpay: the company took its new name in December 2024, keeping the licence and its Zug base.
Designed as an incubator for future banks, the regime has not delivered: no holder has yet converted 1b into a banking licence, and the Chambers Fintech 2026 review calls it not a big success, with at least two early holders liquidated. The instructive case is SWISS4.0 SA: in March 2025 FINMA opened bankruptcy proceedings over the Geneva fintech, and its clients learned in practice what an account without esisuisse means. The lesson is direct: a 1b institution is an operational wallet for payments, not a place to keep substantial balances.
The DLT Act: register securities and two venue models
The DLT amendment package has been in force since 2021 and rests on three elements. First, ledger-based securities: a share or bond is issued directly on a blockchain register, with no depository chain. Second, bankruptcy protection: crypto assets a custodian holds for clients can be segregated from its estate. Third, the DLT trading facility — an infrastructure licence for venues where tokenised securities trade multilaterally and retail investors are admitted directly, without a broker.
Practice assembled more slowly than the law. SIX Digital Exchange obtained exchange and central securities depository licences back in September 2021 — but within the traditional infrastructure perimeter. The first true DLT licence went to BX Digital on 18 March 2025: a small facility with regulatory reliefs, settling securities on Ethereum with a link into the SIC payment system, and offering no custody. Taurus took a third route: its TDX venue runs as an organised trading facility under a securities firm licence, and in 2024 FINMA admitted retail clients to it.
Stablecoins: a bank guarantee instead of a licence
The Swiss construction for issuers is stricter than it looks. A stablecoin redeemable at par is deposit-taking: the issuer needs either a banking licence or a default guarantee from a Swiss bank. FINMA Guidance 06/2024 of 26 July 2024 set minimum requirements for such guarantees — coverage of all deposits including interest, a direct client claim on the guaranteeing bank — and fixed the central point of supervisory practice: the issuer must be able to identify every token holder at any time. Anonymous circulation is treated as an elevated money-laundering risk and a reputational threat to the guaranteeing bank.
Swiss stablecoins therefore live in a whitelisting model — from Dukascoin, issued by Dukascopy, to bank pilots — while global issuers pick other jurisdictions. How the spectrum runs from deposit tokens to MiCA e-money tokens is covered in our guides to stablecoins and the forms of the digital dollar.
The 2025–2028 reform: payment instrument institutions replace 1b
On 22 October 2025 the Federal Council put out for consultation a bill that redraws the ladder's lower rungs. The fintech licence will be replaced by the payment instrument institution (Zahlungsmittelinstitut): the CHF 100 million cap goes, client funds become segregated in insolvency, and stablecoin issuance is expressly permitted. Alongside it comes the crypto institution — a prudential licence for crypto custody and trading modelled on the securities firm regime, but lighter. The consultation closed on 6 February 2026; per Chambers, the package will not enter into force before 2028. The practical consequence: today's 1b or SRO position is a placeholder for conversion — design capital and compliance for the future categories now.
The map of entry points
| Entry point | Holding client money | Capital | Fits |
|---|---|---|---|
| SRO membership (VQF and others) | no — exchange and transfer without balances | no formal minimum | exchangers, OTC desks, wallets: AML supervision without prudential |
| FinTech licence (Art. 1b BankA) | deposits up to CHF 100 million; no interest, no investing | 3% of deposits, minimum CHF 300,000 | payment accounts, collective crypto custody |
| Securities firm + OTF | client assets in securities trading | from CHF 1.5 million | tokenised securities platforms (Taurus TDX) |
| DLT trading facility (FinMIA) | multilateral order book in DLT securities, direct retail access | FinMIA infrastructure requirements | exchange projects (BX Digital) |
| Banking licence | unlimited deposits, interest, lending; esisuisse up to CHF 100,000 | from CHF 10 million | the full product: Sygnum, AMINA, Dukascopy |
The ladder's logic is the right to hold other people's money. A pure VASP — exchange, OTC, non-custodial services — needs only SRO membership with AML duties and the travel rule. Once a client balance appears, you need 1b. Trading tokenised securities takes a securities firm; running your own order book takes a DLT trading facility. Only a banking licence delivers the full product — the route Sygnum and AMINA took in 2019, while Dukascopy added crypto to a working bank. From the depositor's side, the same table reads: tokenised securities belong with a bank custodian or a DLT venue where segregation works; fiat balances beyond operational needs belong in a full bank.
Outside MiCA: passporting only through a subsidiary
Switzerland is not an EU or EEA member, so FINMA cannot issue MiCA licences, and the regulation provides no equivalence for crypto services: a Swiss licence opens no part of the European market. The industry's working answer is subsidiaries. By August 2026, eight Swiss players had obtained CASP authorisations through them: Crypto Finance in Germany (January 2025), AMINA in Austria (October 2025), Relai in France, SwissBorg in March 2026, Swissquote in Luxembourg (April 2026). Liechtenstein — an EEA member with a kindred legal order — became the main gateway: RuleMatch, Bitcoin Suisse and Sygnum all passed through it in June 2026. The mechanics of the European entry are covered in MiCA and the CASP licence guide.
Transparency and central bank money
Two processes set the backdrop to 2028. The first is transparency. The act on automatic exchange of crypto data under CARF has been in force since 1 January 2026: data is already being collected for 2026, with the first exchange scheduled for 2027 with 74 partner states — the entire EU, the UK and most of the G20, minus the US and Saudi Arabia. For a European resident, a Swiss crypto account thus becomes visible to the home tax authority alongside the bank account. In parallel, the adopted AMLA package brings a federal beneficial ownership register; entry into force is slated for the second half of 2026, though the date is not yet final.
The second is infrastructure. The SNB extended Project Helvetia with wholesale CBDC until at least mid-2027: tokenised securities settle in central bank money in production on SDX, and BX Digital received a live connection to SIC for settlement in traditional money. Switzerland is testing the tokenised market on real money rather than in a sandbox — a strong argument in the competition for tokenised private wealth.
Q/A
How does an account with a 1b institution differ from a bank account?
In three ways: no interest, no esisuisse or depositor privilege in bankruptcy, and no right for the institution to invest your money. It is an operational tool for payments, not a store of wealth. The 2025 SWISS4.0 bankruptcy showed the difference: clients ranked as ordinary creditors. The reform will add mandatory segregation of client funds.
Where should a private client keep tokenised securities?
The base option is a bank custodian with crypto capability (Sygnum, AMINA, Dukascopy): since 2021 the DLT package has allowed crypto assets to be segregated from a custodian's bankruptcy estate. Direct exchange access runs via a DLT trading facility — BX Digital settles on-chain but offers no custody — or a Taurus TDX account under a securities firm licence. Registered security plus settlement through SIC already works in production.
Does a Swiss licence open the EU market?
No. Switzerland is outside MiCA, there is no equivalence, and reverse solicitation is construed narrowly. The only route is a subsidiary with a CASP authorisation in the EU or EEA; in practice Liechtenstein became the main gateway, carrying Sygnum, Bitcoin Suisse and RuleMatch through in 2026. Budget for the dual perimeter from the start.
Is it worth applying for the fintech licence now?
It depends on the horizon. The regime is live and FINMA keeps granting licences: Audax Solutions and Sequence entered the register after the reform was announced. But around 2028 the payment instrument institution takes over — no CHF 100 million cap, mandatory segregation — so design capital and compliance for it now. If you do not need client balances, the SRO perimeter or operating under someone else's licence is the more rational path.
This material is an expert overview for information purposes, not individual legal advice. Verify capital thresholds and licence statuses against FINMA registers for your specific project.