Obtain a Cryptocurrency Licence in Switzerland: FINMA & SRO Pathways

Switzerland combines regulatory clarity with operational flexibility, making it a preferred jurisdiction for crypto exchanges, brokers, custodians, and fintechs. Firms may operate under FINMA supervision or as regulated financial intermediaries through FINMA-recognized SROs, enabling a fit-for-purpose approach depending on whether activities involve payment tokens, securities, custody at banking standards, or asset management. Strong AML/KYC expectations and access to Swiss banking and professional services further boost trust and market access. Obtaining a Crypto license in Switzerland ensures full compliance and credibility in this market.

What this guide covers:

• Swiss Regulatory Landscape: The roles of FINMA and SROs, and how crypto assets are classified.
• Licensing Path: A comparison of SRO membership versus direct FINMA authorization.
• Practical Compliance Steps: From incorporation and capital to AML/KYC frameworks and documentation.
• Costs & Ongoing Duties: Clear breakdowns of timelines, expenses, and perpetual obligations.
• The Swiss License Advantage: How a Swiss VASP license builds credibility and offers a strategic edge.

Regulatory Background

Switzerland regulates digital asset activities through its established financial-market framework rather than a standalone crypto statute. This approach provides legal certainty while allowing firms to align their operations with existing financial, AML, and securities requirements. Oversight is coordinated by the Swiss Financial Market Supervisory Authority (FINMA), which sets expectations for risk management, governance, and investor protection across all virtual-asset activities.

FINMA’s Supervisory Role

FINMA does not issue a “crypto-only” license. Instead, it supervises digital asset businesses under the same rules that apply to financial intermediaries, securities firms, and institutions with custody or trading functions.

Key supervisory responsibilities include:

• Interpreting how digital asset activities fall under Swiss financial laws
• Enforcing AML obligations, customer due diligence, and monitoring frameworks
• Assessing when a business must obtain a full financial institution license rather than operate via an SRO

Classification of Digital Assets and Legal Implications

Switzerland uses a functional classification model, and regulatory obligations depend on the nature of the token and related services.

Typical asset categories include:

• Payment tokens: primarily used for transfers; subject to AML rules when intermediated.
• Utility tokens: used to access digital services; may require additional oversight if they have investment-like features.
• Asset or security tokens: represent financial instruments, claims, or rights; typically fall under securities and financial-market regulations.

This classification determines whether firms must register with an SRO as financial intermediaries or obtain direct authorization from FINMA, particularly when custody, trading of securities-like tokens, investment services, or complex financial products are involved.

Licensing Options and Regulatory Pathways for Crypto Businesses in Switzerland

Switzerland offers multiple authorization routes for crypto companies, including SRO membership and direct FINMA authorization (FINMA Guidance on DLT and Virtual Currencies). The choice depends on the type of digital asset handled and the business model. Firms seeking a Swiss crypto license must align with AML Act (AMLA) requirements, implement robust KYC procedures, and demonstrate governance and operational readiness.

SRO Membership (Financial Intermediary Status)

A FINMA-recognized Self-Regulatory Organization (SRO) provides oversight to financial intermediaries that do not require a full financial institution license. SROs enforce Switzerland’s Anti-Money Laundering Act (AMLA) and ensure that member companies maintain proper KYC, monitoring, and reporting procedures.

Typical use cases include:

• Spot, OTC, and P2P crypto exchanges handling payment tokens.
• Brokerage and intermediation services.
• Basic custody arrangements without securities-grade obligations.
• Order execution services for digital assets.
• Fiat-to-crypto and crypto-to-fiat conversion platforms.

For many early-stage or non-securities operations, SRO affiliation provides an efficient, reliable pathway to lawful operation within the Swiss financial system.

Direct FINMA Authorization

Firms must apply directly to FINMA if their services fall under financial-market laws that go beyond basic AML obligations. This authorization mirrors the level of scrutiny applied to traditional securities dealers, asset managers, and custodians.

FINMA authorization is typically required when a business:

• Trades, brokers, or deals in security tokens with characteristics of financial instruments.
• Offers advanced custodial services with banking-level obligations.
• Provides asset management, portfolio management, or operates collective investment schemes involving digital assets.
• Acts as a securities firm, manages order books, or provides regulated trading infrastructure.
• Issues or distributes structured products or tokenized financial instruments.

This pathway is more document-intensive and involves deeper prudential, governance, and capital requirements.

Other Relevant License Types and Corporate Structures

Depending on the business model, Swiss law provides several additional authorization categories that may apply to digital-asset operators:

• Fintech License (Sandbox License): Allows certain financial activities with reduced barriers, including innovative crypto services, provided the firm meets capital and risk-management requirements.
• Banking License: Required when accepting public deposits or providing regulated custody at banking standards.
• Securities-Dealer or Securities-Firm License: Applies to companies trading in securities or security tokens on a professional basis, operating trading venues, or providing structured investment services.

The appropriate pathway depends on the function of the digital asset, the business model, and the level of investor exposure. Selecting the correct regulatory route ensures compliance while optimizing operational efficiency.

Eligibility and Requirements

Switzerland applies rigorous eligibility standards to ensure that crypto businesses entering the market operate with strong governance, transparent ownership, and reliable compliance controls. These requirements apply both to firms pursuing SRO membership and those preparing for direct FINMA authorization.

Company Formation and Corporate Governance

Applicants must establish a Swiss legal entity (GmbH or AG) and register it in the commercial register (Swiss Code of Obligations). This step is essential for a FINMA crypto license or SRO membership. Typical expectations include:

• Clearly defined management roles and organizational structure.
• Demonstrated expertise in digital assets, financial services, compliance, or risk management among directors and key officers.
• Documented internal policies governing operations, data handling, business continuity, and conflict-of-interest management.

These governance elements help demonstrate that the company can operate safely within the Swiss regulatory environment.

Substance, AML Controls, and Transparency Requirements

Regulators require that applicants maintain a meaningful operational presence in Switzerland, along with robust AML/KYC and oversight mechanisms.

Common requirements include:

• A physical office suitable for the activities performed.
• At least one Swiss-resident director to ensure local accountability.
• Appointment of a Swiss-based AML Officer responsible for due diligence, monitoring, and reporting.
• Periodic compliance reviews by a local AML auditor (mandatory under most SRO frameworks).

In addition, firms must maintain full organizational transparency. This includes identifying all beneficial owners, outlining the business model in a detailed business plan, and providing documentation for AML/KYC procedures, internal risk controls, technology infrastructure, and data-security frameworks. Together, these requirements position the company to meet Swiss expectations for integrity, compliance, and operational readiness.

The Swiss Path to VASP Authorization: A Step-by-Step Guide

Switzerland’s licensing and registration process is structured to evaluate a company’s business model, governance, and compliance readiness before it begins providing crypto-related services. The steps differ depending on whether the firm pursues SRO membership or direct FINMA authorization, but the core sequence remains consistent.

Step 1: Determine the Appropriate Regulatory Pathway

Applicants must first assess whether their planned activities fall under SRO oversight (financial intermediary status) or require full FINMA licensing. The decision is based on the nature of the assets handled and the complexity of the services.

Key factors to consider include:

• Whether the business deals only with payment tokens or also with security tokens.
• Whether custody is basic (transactional) or bank-grade with deposit-taking features.
• Whether services include asset management, trading infrastructure, or collective investments.

This analysis shapes the entire licensing strategy and documentation package.

Step 2: Establish a Swiss Legal Entity

Before submitting any application, the company must be incorporated in Switzerland. The most common structures for crypto firms are GmbH and AG.

During incorporation, firms must prepare:

• Articles of association tailored to digital-asset operations.
• A management structure with clearly assigned roles.
• Identification and verification documents for shareholders and directors.

Once entered into the commercial register, the company can proceed with filing its regulatory application.

Step 3: Prepare Documentation and Compliance Framework

The core of the licensing process is the development of policies, procedures, and evidence that the company can operate in a controlled, compliant environment.

Required documentation often includes:

• A detailed business plan describing products, technology, risk exposures, and customer segments.
• AML/KYC policies covering onboarding, monitoring, sanctions checks, and reporting.
• Governance, internal-control, and risk-management frameworks.
• IT and cybersecurity policies addressing system security, data protection, and continuity measures.

For SRO membership, these materials must align with AMLA requirements; for FINMA licensing, controls must meet stricter prudential standards.

Step 4: Submit the Application to the SRO or FINMA

Once the compliance package is complete, the company submits it to the appropriate authority.

• SRO path: the SRO reviews the AML framework, governance setup, staffing, and internal controls.
• FINMA path: FINMA conducts a deeper, more technical assessment, including governance, financial soundness, custodial arrangements, and treatment of security tokens.

Regulators may request clarifications or additional documentation, especially for high-risk services or innovative models.

Step 5: Respond to Regulatory Feedback and Finalize Approval

Both SROs and FINMA typically follow an iterative review process. Applicants must be prepared to refine their frameworks and address questions promptly.

Typical follow-up requests may involve:

• Adjustments to AML procedures or monitoring thresholds.
• Additional detail on custody arrangements or technology partners.
• Updated governance documents or expanded risk assessments.

Once all issues are resolved, the SRO issues membership confirmation or FINMA grants authorization, allowing the business to begin operations within Switzerland’s regulated environment.

Costs and Capital Requirements

Building a compliant crypto business in Switzerland requires sufficient capitalization, predictable budgeting for regulatory obligations, and an understanding of how operational scope affects financial thresholds. FINMA does not impose a single uniform capital requirement for all Virtual Asset Service Providers (VASPs); instead, capital expectations derive from the chosen legal form, business model, and the financial risks associated with services such as custody, trading, or tokenization. The following elements outline the primary cost drivers for market entry and ongoing operations.

Share Capital Requirements

Swiss company law establishes minimum capital thresholds that every applicant must meet before seeking regulatory approval. These serve as baseline corporate requirements and may be supplemented by additional FINMA expectations depending on the risk profile of the activity.

• GmbH (LLC): Minimum share capital of CHF 20,000.
• AG (Joint-Stock Company): Minimum share capital of CHF 100,000, with at least CHF 50,000 paid in incorporation.
• Higher thresholds apply when licensed activities entail customer asset custody or securities-related functions, as prudential risk controls become part of the evaluation.

Compliance and Operational Costs

Beyond statutory capital, applicants must prepare for extensive compliance and technical infrastructure costs. Switzerland maintains a supervisory environment aligned with international AML and financial integrity standards, and applicants are expected to demonstrate credible long-term operational readiness.

Typical cost components include:

• AML/KYC Framework: Deployment of verification systems, transaction monitoring tools, sanctions-screening modules, and automated risk scoring.
• Personnel: Appointment of a qualified AML Officer, internal compliance staff, and (when applicable) risk management and internal audit functions.
• Annual External Audit: Mandatory for most regulated entities; costs rise with business complexity.

Additional Requirements for Higher-Risk Models

Projects involving asset custody, token issuance, securities-linked products, or digital asset trading engines are subject to higher expectations for financial stability and institutional robustness. In such cases, FINMA may require:

• Enhanced minimum capital buffers proportional to operational risk.
• Stronger governance structures, including board members with sector-specific expertise.
• Additional reporting and internal control layers, particularly for firms handling client assets or executing trades.

Swiss Taxation Snapshot for Crypto Businesses

Licensing Timeline: Key Stages and Expected Duration

Establishing a crypto business in Switzerland follows a structured regulatory sequence, with processing times varying depending on whether the application is submitted through an SRO (Self-Regulatory Organization) or directly to FINMA. While SRO affiliation generally offers a faster route for AML-regulated activities, FINMA authorization applies to firms engaging in higher-risk or prudentially supervised services. Below is a consolidated overview of the typical timeline applicants can expect.

Advantages of Switzerland as a Jurisdiction for Crypto Businesses

Switzerland has built one of the world’s most mature environments for digital asset operations, combining strong regulatory certainty with a business infrastructure designed for financial institutions. Its blend of legal clarity, predictable supervision, and competitive taxation makes it a preferred location for exchanges, custody providers, trading platforms, and blockchain-driven fintechs.

Key advantages include:

• Clear, technology-neutral regulation: Crypto activities are governed under established financial and AML laws, providing transparency without requiring a “special” crypto license.
• Credible oversight by FINMA: Internationally respected supervision strengthens institutional trust and facilitates cross-border partnerships and banking relationships.
• Flexible licensing pathways: Businesses can operate under SRO membership or pursue direct FINMA authorization, allowing scalability depending on services offered.
• World-class financial ecosystem: Switzerland hosts robust banking, legal, auditing, and compliance service providers, supporting complex crypto operating models.
• Attractive tax and business environment: Competitive corporate tax rates, exemptions for many crypto transactions, and stable political and economic conditions.
• Strong talent and innovation hubs: Regions such as the Crypto Valley (Zug) provide access to experienced professionals, investors, and blockchain initiatives.

How Gofaizen & Sherle Can Assist

Obtaining a crypto license in Switzerland requires precise preparation, a sound regulatory strategy, and documentation that aligns with FINMA or SRO expectations. Gofaizen & Sherle supports applicants across every phase of the process, ensuring that their internal framework, governance, and compliance standards meet Swiss regulatory requirements.

Our support includes:

• Company formation and structuring
  We assist with establishing a Swiss legal entity (AG or GmbH), organizing shareholder and governance structures, and completing all statutory registrations necessary for regulatory onboarding.
• End-to-end licensing support
  Our team prepares and files the full application package, manages communication with the chosen SRO or FINMA, and helps address follow-up inquiries to maintain momentum throughout the review.
• Regulatory documentation and compliance design
  We develop tailored business plans, AML/KYC frameworks, risk management policies, and operational procedures that meet Swiss supervisory standards and reflect the client’s service model.
• Specialized expertise in digital asset regulation
  Our professionals advise crypto exchanges, custodians, brokers, tokenization platforms, and other fintech providers across multiple jurisdictions, bringing deep knowledge of cross-border regulatory practice.
• Compliance training for employees
  We create and deliver training programs that help staff meet AML and operational compliance obligations, supporting long-term regulatory readiness.
• Ongoing corporate support and maintenance
  From accounting oversight and reporting to communication with authorities and updates to internal policies, we provide continuous assistance to ensure that the company remains compliant after licensing.

Partnering with Gofaizen & Sherle strengthens the quality of your application and accelerates your progress through Switzerland’s regulatory framework, giving your business a reliable foundation in one of the world’s leading crypto jurisdictions.

For advice on Crypto license in Switzerland, contact our specialists at еmail: info@gofaizen-sherle.com — they will provide professional support, help you choose the optimal regulatory path, and prepare all the necessary documents for obtaining a license.