Fintech and crypto businesses
Consulting on the Swiss licensing route for financial-sector businesses, including the SRO pathway.
If your business handles client assets, exchanges or transfers value, or issues tokens, Swiss financial-market law may require you to be affiliated with a self-regulatory organisation or licensed by FINMA. We advise on which regime applies and what it will demand of your structure, before you incorporate, not after.
The SRO route, briefly
Switzerland has no single crypto licence. Exchange, brokerage, custody and payment models are generally treated as financial intermediation under the Anti-Money Laundering Act, which requires affiliation with a FINMA-authorised self-regulatory organisation before activity begins. This is the reality behind the phrase "Swiss crypto licence".
Once affiliated, this route generally covers fiat payment services, crypto transfers and wallets, stablecoins, currency exchange between fiat and crypto, custody, and card issuance through a banking partner, plus direct onboarding of Swiss clients without needing a separate foreign entity. It sits under an AML-supervised regime rather than a full banking or securities licence, with a ceiling on public deposit-taking; businesses that expect to outgrow that ceiling plan an early move to a higher-capacity FINMA licence tier instead.
What the licence generally covers
Fiat payment services
Pay-in, pay-out, transfers and settlement.
Crypto transfers, wallets & stablecoins
Held and moved under the same AML-supervised regime, there is no separate crypto licence in Switzerland.
Currency exchange
Fiat to fiat, fiat to crypto, and crypto to crypto.
Custody
Segregated or pooled holdings, with disclosure duties attached to pooled holdings.
Card issuance
Through a banking partner.
Direct onboarding of Swiss clients
No separate foreign entity needed to serve the Swiss market.
What we advise on
Regulatory classification
Whether the intended activity falls within scope, and under which regime.
Corporate structuring for the route
Entity form, capital, purpose clause and governance shaped around the licensing requirement rather than retrofitted to it, including the resident-director requirement, which most founders meet through a nominee arrangement rather than relocating themselves.
Requirements mapping
What the chosen route expects in terms of organisation, resident representation, and documentation, including that a Switzerland-based AML Officer is a requirement of the licence.
Incorporation and administration
The corporate work itself, under our standard mandates.
SRO membership filing
We prepare and file the membership application with the relevant self-regulatory organisation on your behalf; membership itself sits with your business.
- 01Do I need an SRO affiliation?
- It depends on the activity, not the label. Financial intermediation as defined by Swiss law triggers the requirement; many businesses that describe themselves as fintech fall outside it. That determination is the first thing we do.
- 02Can I incorporate first and sort out licensing later?
- You can, and it is usually the more expensive order. Purpose clause, capital and governance are all easier to set correctly at incorporation than to amend afterwards.
- 03Do you handle FINMA licence applications?
- No. We advise on the route and on structuring. Licence applications are handled by specialist regulatory counsel.
- 04Do I need a Switzerland-based AML Officer?
- Yes, it is a requirement of SRO membership. RPCS does not act as your AML Officer; we point you to specialist providers who take on that role.
- 05What happens if my business outgrows the SRO route?
- The SRO route carries a ceiling on public deposit-taking. Businesses that expect to exceed it plan an early move to a higher-capacity FINMA licence tier instead of retrofitting the structure later.
Related services
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