FinIA Reform: SRO to Direct FINMA Supervision

Switzerland's Federal Council has proposed a reform that would move most SRO-supervised crypto and payment firms onto direct FINMA supervision instead. The consultation on the underlying law closed in February 2026, and while nothing has taken effect yet, the direction is now clear enough that a founder currently planning around SRO membership should understand what is being proposed and why.

What the Federal Council has proposed#

On 22 October 2025, the Federal Council opened a consultation on an amendment to the Financial Institutions Act (FinIA) introducing two new licence categories: payment institution and crypto institution. The consultation closed on 6 February 2026, and the submissions are now under review inside the federal administration.

The two new licence categories#

The payment institution category is designed to replace the existing Fintech licence under Article 1b of the Banking Act, the "innovation licence" that currently lets a firm accept public deposits without becoming a bank, capped at CHF 100 million. Under the proposal, that cap is removed, and the category is explicitly extended to cover the issuance of value-stable crypto-based means of payment, in other words stablecoins.

The crypto institution category is new. It is aimed at firms providing custody (including staking), customer trading, short-term proprietary trading, and crypto exchange services, built on requirements modelled on those for securities firms, though less extensive since crypto institutions do not deal in financial instruments in the traditional sense.

Why this matters for SRO-supervised firms#

The part of the reform that matters most for a crypto or payment firm currently working through an SRO is the supervision model itself. Firms that fall into either new category would be brought under direct FINMA supervision, rather than the self-regulatory organisation model that currently covers most of Switzerland's crypto financial intermediaries for anti-money-laundering purposes. That is a materially different relationship: FINMA supervision is more direct and, by most accounts from firms already dealing with FINMA elsewhere, more intensive than SRO oversight.

This does not mean SRO membership disappears for every type of financial intermediary, or that every crypto business today is affected identically. What it means is that a firm sizing up its licensing route now has a reason to look past the current SRO/FINMA divide and ask which side of it its business model would sit on once, and if, this reform is enacted.

What happens next#

The Federal Council has not yet published its dispatch to parliament. Once it does, the proposal moves into ordinary parliamentary deliberation, which sets its own timeline. No entry-into-force date exists yet, and it would be inaccurate to state one. The one date that is fixed is behind us: the consultation itself closed on 6 February 2026.

For a founder planning a Swiss crypto or payment business today, the practical takeaway is not to wait for the reform, since there is no firm date to wait for, but to build the licensing plan with an awareness that direct FINMA supervision, not SRO membership, may be the eventual destination for this category of business.

Information current as of 13 August 2026, based on the Federal Department of Finance's State Secretariat for International Finance (sif.admin.ch).