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Crypto Licence Switzerland

Learn everything about the Swiss crypto licence — eligible activities, application process, regulatory requirements (including substance in Switzerland), key limitations, and more.
SRO Membership Guide
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Does Switzerland have a crypto licence? 

Switzerland does not offer a dedicated “crypto licence” as found in the EU under MiCA regulations. Instead, it was one of the first jurisdictions back to 2018 to adopt a technology-neutral approach — including toward blockchain. As a result, crypto-related activities are assessed under existing Swiss financial laws, particularly anti-money laundering (AML) legislation, rather than a standalone crypto-specific law.

In practice, the vast majority of crypto activities — or those involving blockchain-based technologies — are regulated primarily from an AML perspective. This means that most such businesses must be affiliated with a self-regulatory organisation (SRO) recognised by FINMA, the Swiss Financial Market Supervisory Authority. This requirement is commonly referred to as an SRO membership or SRO licence. So next time you hear about the Swiss crypto licence, remember — it's actually an SRO membership. For simplicity, we’ll refer to it as the 'Crypto Licence' on this page.

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Key Advantages of getting a crypto licence in Switzerland

The so-called Swiss crypto licence — i.e. as explained above formally a membership with a FINMA-recognised self-regulatory organisation (SRO) — offers several practical advantages. This is one of the main reasons why many crypto companies have chosen to establish themselves in Zug, Switzerland, known as the Crypto Valley.

Key benefits include:
  • A flexible regulatory environment: Compared to a full FINMA licence, SRO membership offers a lighter framework that fosters innovation.
  • Faster application process: Applications are often processed quickly, with a high approval rate, if the applicant has a strong AML (anti-money laundering) framework.
  • Global credibility: The Swiss SRO licence is widely recognised internationally and helps boost trust among clients by demonstrating full compliance with Swiss standards.
  • Handling of USDT: Unlike in the EU, SRO members may engage with stablecoins such as USDT, expanding operational possibilities.
  • Light substance requirements: The relatively low onshore substance expectations in Switzerland enable companies to operate from Switzerland with limited OPEX — a clear contrast to MiCA’s more bureaucratic and rigid framework.
  • Dual activity under one roof: An SRO membership allows firms to combine payment services (PSP) and virtual asset services (VASP) under a single legal entity — a key operational advantage.

Which financial services can be offered with a crypto licence in Switzerland?

As an SRO member active in the crypto space, you may engage - in addition to traditional financial intermediation - in a range of financial activities such as:
  • Crypto exchanges (on/off ramp)
  • Crypto custody with individual wallets
  • Crypto wealth management
  • Crypto brokerage
  • Issuing cryptocurrencies such as payment tokens (ICO, TGE)
  • Operating a DEX platform with a permanent business relationship with clients
  • Crypto remittance
  • Crypto payment processing
  • Crypto lending operations
  • All traditional non-crypto financial intermediation activities (e.g. payment processing, lending, remittance, accepting client funds – subject to sandbox limitations or other exemptions, dealing in gold or other precious metals, and more).
Unsure whether the crypto licence fits your business? Contact us today.
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Crypto Licence Application Process Overview

The application process to get a crypto licence in Switzerland, i.e. a SRO membership, consists of three main steps:

Step 1: Company incorporation & business plan drafting

Once the Swiss company has been incorporated, a short business plan must be prepared outlining the intended activities. At this stage, we also assess whether the planned services fall within the scope of an SRO membership or require a FINMA licence instead.

Step 2: Completing application forms and collecting documents

We complete all SRO application forms and gather the necessary personal documents for the directors and AML Officer, and draft the AML & CTF policy and processes. A check list of the documents required for the SRO membership application can be found here (VQF example).

Step 3: Application submission to the SRO

Once the application file is complete, we submit it to the selected SRO for review – we typically work with VQF. The SRO will assess the request, focusing primarily on the AML framework. They often invite the applicant for a video call to discuss the project and may request additional clarifications.

Step-by-step overview of the SRO membership licensing process
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FQA: Swiss Crypto licence

In principle, it is essential that the company has a genuine presence in Switzerland. Shell companies are not permitted, and dormant SRO members are no longer accepted under FINMA’s latest practice.

In practice, the minimum substance requirements generally include:

  • A local director based in Switzerland

  • A Swiss-based AML Officer (second line of defence)

  • A physical office in Switzerland (typically not a shared office; a dedicated space is preferred)

  • A Swiss-based employee once the company becomes active and grows

  • A local AML auditor (mandatory requirement)

No, there is no limit on crypto transfers or the amount held in custody with individualized and segregated wallets (one wallet per client). There are also no limits on fiat-to-crypto, crypto-to-crypto, or crypto-to-fiat exchanges.

As a company based in Switzerland and regulated under Swiss law, MiCA (Markets in Crypto-Assets Regulation) is not directly applicable. However, MiCA may become relevant if you provide cross-border crypto services targeting clients in the European Union. In such cases, Swiss companies must carefully assess whether their activities fall within the scope of MiCA and whether local compliance requirements (such as reverse solicitation exemptions or licensing needs) apply.

No, since Switzerland is not part of the European Union, EU passporting is not available to Swiss-licensed entities. However, this does not mean that cross-border activities are prohibited. Swiss companies may still serve EU-based clients, but must carefully assess the legal and regulatory requirements in each relevant EU member state, particularly when actively soliciting clients or offering services in the EU.

Yes. Unlike under MiCA regulations in the EU, USDT is not prohibited in Switzerland and can be freely used and offered to clients without issue.

At least one local director with individual signing authority is required.

Yes, an SRO membership allows for the combination of crypto and payment activities under the same entity. This is one of the advantages, as it effectively combines the roles of a PSP (Payment Service Provider) and a VASP (Virtual Asset Service Provider) within the same company.

In Switzerland, there is no MLRO as in the EU framework. Instead, the equivalent role is referred to as the AML Officer, whose responsibilities are very similar. The AML Officer oversees the second line of defence and monitors the activities carried out by the first line (i.e., business operations and client onboarding). This role must be performed either by a local AML Officer employed by the company or outsourced to a Swiss-based AML professional. Depending on the size and complexity of the business, a deputy AML Officer may also be required.

In general, companies starting their operations in Switzerland choose to outsource their AML second line of defence to an external Swiss AML Officer. SynHedge benefits from privileged relationships with reputable local AML service providers, ensuring smooth and compliant onboarding.

No, offering Contracts for Difference (CFDs) or any other derivative products generally falls outside the scope of a Swiss crypto licence (i.e., SRO membership). These activities are considered regulated under Swiss financial market law and typically require a FINMA licence.

It depends on your business. For companies focused on payments or crypto, we typically work with VQF or SO-FIT. We will guide you through the selection process.

There is no regulatory capital requirement for SRO membership, meaning no buffer must be maintained as with banks. However, establishing a company in Switzerland requires a capital contribution. A Ltd company (AG, SA) requires CHF 100,000 in capital, with at least CHF 50,000 paid up at incorporation. For an LLC (GmbH, SARL), the capital is CHF 20,000, and it must be fully paid. This capital can generally be used by the company for its activities, though certain corporate law requirements (Art. 725 CO) regarding governance must be followed, especially in cases of capital loss or over-indebtedness.

The affiliation process, once the application is submitted to the SRO, generally takes between 1 to 3 months, depending on the case. The SRO will specifically assess the anti-money laundering framework and ensure the fitness and properness of the AML officer (who can be outsourced) as well as the external AML auditor. SynHedge will connect you with all the necessary parties. The SRO license is particularly valued for its swift approval process. 

Yes. Although English is not an official language in Switzerland, it is widely used in the financial sector. The entire application process can be conducted in English, and the required documents may be submitted in English. Most SROs provide English-language forms and are accustomed to reviewing documentation in English.

Yes, an SRO member can apply for a FINMA license. Once obtained, the SRO membership becomes unnecessary, as all financial activities of the company, including AML compliance, fall under FINMA’s direct supervision. Effectively, the FINMA license replaces the SRO membership.

Do not hesitate to reach out. We’ll be happy to answer your questions and assess how we can best support you. Book a call now or email us at info@synhedge.com

SynHedge As Your Swiss Legal & Regulatory Partner

SynHedge supports you throughout the entire authorization process and beyond. We guide you through each step, ensuring compliance and efficiency. Additionally, SynHedge connects you with all the necessary parties to ensure you meet the Swiss substance requirements. We work exclusively with local partners specialized in this field.
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