SynHedge logo white

Payment institution license Switzerland

Learn everything about the licensing requirements for payment institutions in Switzerland — permitted activities, application process, regulatory requirements, substance in Switzerland for Swiss payment service providers, and more.
Send Us Your Request

How are payment institutions (PI) regulated in Switzerland?

Switzerland does not have a Payment Institution (PI) licence regime like the one in the European Union or the United Kingdom. The Swiss Financial Market Supervisory Authority (FINMA) does not issue a specific payment institution licence.

Instead, in Switzerland payment service providers must operate under a Self-Regulatory Organisation (SRO) membership. An SRO is a private supervisory body authorised by FINMA to oversee its members, primarily for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance.

By becoming a member of an SRO —such as VQF or SO-FIT— payment institutions can provide a wide range of payment services in Switzerland that, under Swiss law, are regulated only from an AML perspective and do not require a separate FINMA licence. This includes, for example:

  • Payment processing for merchants and businesses

  • Money remittance and cross-border transfers

  • Payment card schemes and related infrastructure

  • Other AML-covered payment activities (full list below)

Send Us Your Request

What activities may be offered with as a Swiss payment institution?

As a payment service provider in Switzerland —operating under SRO membership— you can generally perform any financial intermediation activity that is regulated solely from an Anti-Money Laundering (AML) perspective, without requiring a FINMA banking or fintech licence 1b. This typically includes (non-exhaustive list):
  • Money remittance services (domestic and cross-border transfers)
  • Merchant payment processing (online and in-store)
  • Card acquiring and merchant acquiring services
  • Issuing of prepaid cards or payment cards
  • Mobile payment solutions (e.g., QR code payments, NFC-based systems)
  • E-wallet services that do not involve deposit-taking
  • Payment gateway services for e-commerce platforms
  • Currency exchange (fiat-to-fiat) linked to payment transactions
  • P2P payment services (peer-to-peer transfers)
  • Corporate payment solutions and payroll disbursements
  • Bill payment and collection services
  • Processing of recurring subscription payments
  • White-label payment infrastructure for third parties
  • Payment aggregation for small merchants or resellers
  • Payment initiation services without account-holding
  • Cash-in / cash-out services for prepaid balances or vouchers
In addition to traditional payment activities, a member of an SRO may also offer, under the same regulatory framework — without requiring a second license — a broad range of services in the crypto space and in finance, including but not limited to:
  • Crypto payment processing incl. USDT, Crypto exchanges (on/off ramp of both crypto and fiat), Custody of crypto with individual segregated wallets, Performing ICO / TGE of cryptocurrencies, Remittance in crypto, Crypto lending operations, and more...
  • Gold or precious metals trading, loan or leasing issuance, commodities trading, and more
If you want to know precisely whether the activities you offer can be carried out as an SRO member or require a FINMA license, please contact us. Take advantage of a free consultation call.
Schedule a Free Call

What are the benefits of getting a payment institution licence in Switzerland?

The so-called payment institution licence — which, as explained above, formally corresponds to membership in an SRO — provides several practical advantages. Key benefits include:
  • Enables provision of both payment and crypto services under the same licence (no need for separate licences as in the EU).
  • Provides a clear, stable, and flexible regulatory framework
  • Allows the offering of USDT stablecoins
  • Streamlined affiliation process in English (way less burdensome than a MiCA licence)
  • Enhances international credibility, as the regime is widely recognised
  • Relatively low substance requirements in Switzerland

How to become a licensed payment institution in Switzerland – step-by-step process

As a payment service provider in Switzerland, you are required to obtain membership with one of the 11 FINMA-recognized SROs. SynHedge can assist you in selecting the SRO that best fits your business case. The SRO membership process consists of three key steps:

Step 1: Company Incorporation in Switzerland and Drafting a Short Business Plan
To apply for SRO membership, it is essential that the payment service provider incorporates a company in Switzerland, typically a GmbH or AG. This process is usually quick and can be completed within 1 to 2 weeks. Simultaneously, a concise business plan must be prepared, clearly detailing the activities the PSP intends to conduct. At this stage, we also assess whether these activities can be performed under a simple SRO membership or if a FINMA license is required.

Step 2: Preparation of the SRO Membership Application
Once the company is incorporated — or in parallel to avoid delays — the SRO membership application must be prepared. This includes completing several questionnaires, providing supporting documents such as criminal record extracts, CVs, passports, etc., and drafting an AML policy. It is also necessary to discuss the compliance framework and decide whether to appoint a local MLRO (AML officer) or outsource this function to an approved third-party provider. SynHedge supports you throughout these steps and drafts your AML policy. This stage can be completed within a few days.

Step 3: SRO Membership Application Review
After submitting the completed application to the SRO, the organization will review the documents and usually ask some additional questions about the processes. The applicant is typically invited to a call to present themselves and their business case. This step is mandatory to ensure genuine substance in Switzerland. The review period generally takes between 1 and 3 months from application submission to final decision.

Step-by-step overview of the SRO membership licensing process
Send Us Your Request

Everything You Need to Know About the Swiss Payment Institution Licence

After submitting your application to the SRO for evaluation, the membership approval usually takes from one to three months, depending on the complexity and specifics of your case.

FINMA’s supervisory framework does not permit inactive SRO members or shell companies; therefore, firms must establish a substantive operational footprint in Switzerland. To comply with these standards, applicants need to implement the following essential substance requirements:

  • Designate a Swiss-based AML Compliance Officer responsible for overseeing second-line controls.

  • Secure the services of a local AML auditor, which is mandatory under the SRO regulations.

  • Appoint a director residing in Switzerland who is actively engaged in the company’s governance and oversight functions.

  • Set up a dedicated office space within Switzerland; shared office arrangements are generally discouraged.

  • Employ at least one Swiss-based staff member once the business operations begin to grow.

Swiss companies regulated under domestic financial laws are not directly governed by the EU’s Markets in Crypto-Assets Regulation (MiCA), since it exclusively applies within the European Union. Nevertheless, MiCA may become applicable if a Swiss firm offers crypto-related services or markets digital assets to customers based in EU countries. In these situations, it is crucial for Swiss crypto businesses to assess whether their operations fall under MiCA’s jurisdiction, consider potential exemptions like reverse solicitation, and understand if they must comply with licensing obligations in the relevant EU jurisdictions.

As a payment institution operating under a FINMA-recognised SRO such as VQF, there are no legal limits on the volume of crypto transfers or the value of payments and digital assets held in custody, provided these assets are managed using segregated and individualized wallets.

Yes, it is possible for a single entity to operate both as a Payment Service Provider (PSP) and a Virtual Asset Service Provider (VASP) under the same licence.

Yes, the entire membership process with the SRO can be conducted in English, including the submission of all required documents. Additionally, all SRO forms are available for download in English.

Swiss SRO members, such as those registered with an SRO, do not have EU passporting privileges because Switzerland is outside the European Union. Consequently, regulatory approvals obtained in Switzerland do not provide automatic entry to EU markets. Nonetheless, Swiss firms can still offer services to clients located in the EU on a cross-border basis. It is essential for these companies to perform thorough legal and regulatory assessments in each EU country where they intend to operate, particularly if they are actively promoting their services or conducting business development within those jurisdictions.

Members of an SRO have the option to pursue a direct licence from FINMA if their business operations necessitate it. Upon receiving this licence, the company’s affiliation with the SRO is terminated, and FINMA assumes direct regulatory oversight over all relevant activities.

One local director with individual signing authority (at least). 

Yes, SRO members are legally required to designate an AML Officer (similar to a MLRO) to comply with Swiss regulatory obligations. This officer acts as the second line of defense by overseeing and monitoring the anti-money laundering processes carried out by the first line, such as client onboarding and daily business operations. The AML Officer position must be held by a qualified person who is either: (1) Employed directly by the company and based in Switzerland, or (2) Outsourced to a Swiss-based AML expert or service provider. Depending on the size and complexity of the company’s operations, appointing a Deputy AML Officer might also be required.

Unlike banks or licensed financial institutions, members of a Self-Regulatory Organisation (SRO) in Switzerland are not required to maintain a regulatory capital buffer. This makes the SRO membership route more accessible for many payment service providers and financial intermediaries.

However, Swiss corporate law imposes minimum share capital requirements for establishing a legal entity:

  • Swiss GmbH (LLC / SARL): Requires a fully paid-in share capital of CHF 20,000.

  • Swiss AG (Ltd / SA): Requires a minimum share capital of CHF 100,000, of which at least CHF 50,000 must be paid up at incorporation.

This corporate capital generally supports the company’s operational needs, such as staffing, infrastructure, and service delivery.

Swiss corporate governance rules, notably Article 725 of the Swiss Code of Obligations (CO), impose specific duties on the board of directors concerning capital adequacy. In particular, if the company experiences (i) Capital loss (when net assets fall below half of the share capital) or (ii) Over-indebtedness (liabilities exceed assets), the board must promptly take appropriate measures to protect creditors, such as calling a shareholders’ meeting, filing for restructuring, or liquidation.

No, that’s positive news. USDT (Tether) is not banned in Switzerland and may be freely utilized and offered to clients by payment institutions without any restrictions.

Feel free to get in touch with us. We’re here to answer your questions and explore how we can assist you effectively. Schedule a free call today (go to CONTACT) or contact us via email at info@synhedge.com

SynHedge – Your Expert Support for Payment Services and SRO Membership in Switzerland

SynHedge has developed deep expertise in Swiss payment services and the process of obtaining Self-Regulatory Organisation (SRO) membership, essential for operating compliant payment businesses in Switzerland.

We provide end-to-end assistance including: Company formation and registration in Switzerland, Drafting and implementation of AML (Anti-Money Laundering) policies and compliance documents, Detailed business case analysis tailored to Swiss regulatory requirements, Local support to ensure you meet Swiss substance and operational criteria.

Our transparent and competitive fee structure ensures you know exactly what to expect.

Contact SynHedge today for expert guidance and reliable support to navigate Switzerland’s payment service regulations and successfully obtain your SRO membership.
Send Us Your Request
Imprint
Terms of Use
Privacy Notice
Contact

Copyright © SynHedge LLC - 2025

Synhedge Logo Black

Copyright © SynHedge LLC - 2025

Synhedge black logo