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VQF Licence Switzerland

Learn everything about the VQF Licence in Switzerland — permitted activities, application process, regulatory requirements, substance in Switzerland, SRO information, and more.
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What is the so-called VQF license?

In the international payments industry, terms such as EMI licence, MSB registration (Canada), and VQF licence (Switzerland) are commonly used. However, the expression "VQF licence", while widespread in industry jargon, is legally inaccurate in the Swiss context.

In reality, the so-called VQF licence refers to a company’s membership with the self-regulatory organisation (SRO) VQF — short for Verein zur Qualitätssicherung von Finanzdienstleistungen. It is therefore more appropriate to refer to this as a VQF SRO membership, not a licence.

VQF is one of the SROs officially recognised by FINMA, the Swiss Financial Market Supervisory Authority. Financial intermediaries — especially those active in payment services, crypto/blockchain activities, or other financial intermediation services — must obtain SRO membership in order to operate legally under Swiss anti-money laundering (AML) regulations.

By becoming a member of VQF, a company can lawfully engage in a wide range of regulated financial intermediation activities (see examples below). This is what many practitioners informally refer to as a “VQF licence”, though no such formal licence exists under Swiss law.

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What is VQF and what is its role within the Swiss financial market?

VQF, short for "Verein zur Qualitätssicherung von Finanzdienstleistungen", is a Self-Regulatory Organisation (SRO) officially recognised by the Swiss Financial Market Supervisory Authority (FINMA).

VQF is a organized as a private association under Swiss law, but it operates within a public legal framework defined by the Swiss Anti-Money Laundering Act (AMLA).

It is authorised by FINMA to supervise financial intermediaries who are not directly supervised by FINMA such as for example banks, broker dealers.

In practice, VQF serves as a supervisory body for its members ensuring compliance with AML regulations and financial industry standards.

VQF's key mission is to ensure that its members:

  • Comply with the AMLA and related obligations,

  • Implement robust internal anti-money laundering (AML) and counter-terrorism financing (CTF) procedures,

  • Adhere to high standards of quality in the delivery of financial services

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What activities may be offered with the VQF licence?

Members of the VQF SRO – as is the case with any of the eleven FINMA-recognised SROs (e.g., SO-FIT, PolyReg, etc.) – may carry out a wide range of financial intermediation activities. The following is a non-exhaustive list:
  • Payment processing
  • Lending / leasing operations
  • Accepting clients' funds to some extend (within sandbox (CHF 1mio) or other exemptions)
  • Card issuing and/or acquiring
  • 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 fiat / crypto
  • Dealing in gold or other precious metals
  • Crypto brokerage
  • Crypto lending operations
  • More..
Wondering whether your activity can be carried out under a VQF membership? Contact us to assess your eligibility.
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What are the benefits of getting a VQF licence?

The so-called VQF licence — i.e. as explained above formally a membership with the SRO VQF— offers several practical advantages. 

Key benefits include:
  • 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
  • Enables provision of both payment and crypto services under the same licence (no need for separate licences as in the EU).

What is the process for obtaining VQF membership and securing the so-called VQF licence?

The VQF Membership Process: Three Key Steps

Step 1: Company Incorporation & Business Plan
The process begins with the incorporation of a Swiss company (AG or GmbH). Once the company is established, a concise business plan must be prepared in line with VQF requirements. As part of this phase, it is also necessary to assess whether the intended services require a FINMA licence or whether VQF membership (SRO affiliation) is sufficient. In practice, this step typically takes between 2 to 3 weeks.

Step 2: Completion of VQF Application Forms
The next phase focuses on completing the official VQF membership application. This involves filling out several forms relating to the company’s planned activities, its AML function, and providing standard supporting documents (e.g., CVs, criminal record excerpts, passport copies, etc.). At this stage, the AML policy is also drafted, and either a local AML officer is appointed or compliance is outsourced to a Swiss-based service provider. We support you throughout this entire process. In most cases, this step takes one to two weeks, and for applicants who are well-prepared, it can be completed within a few days. NB: A check list of the documents required for the SRO membership application can be found here (VQF example).

Step 3: VQF Review & Approval Procedure
Once the application file is complete, we submit it to VQF for review and approval. VQF will examine the documentation and may request further clarifications. It is common for the SRO to invite the applicant to a video call to introduce their business model and answer questions.
This affiliation procedure usually takes between 1 and 3 months, depending on the complexity of the application and the responsiveness of the applicant.

Step-by-step overview of the SRO membership licensing process
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Everything you need to know about the so-called VQF licence - FAQ

Yes, all VQF members are legally required to appoint an AML Officer as part of their regulatory obligations in Switzerland.

While the Swiss legal framework does not explicitly refer to a "Money Laundering Reporting Officer" (MLRO) as in the UK or EU, the role of the AML Officer under Swiss law is largely equivalent in function and responsibility. The AML Officer is responsible for the second line of defence, providing oversight and monitoring of the activities performed by the first line (i.e., client onboarding and business operations).

This role must be filled by a qualified individual who is either:

  • Employed directly by the company and based in Switzerland, or

  • Outsourced to a Swiss-based AML professional or service provider.

Depending on the complexity and size of the business, the appointment of a Deputy AML Officer may also be required.

Once the application is submitted to VQF for review, the membership approval process typically takes between 1 and 3 months, depending on the complexity of the case.

Yes. The entire membership process with VQF can be conducted in English, and the documents be submitted in English. All VQF forms can be downloaded in English.

While FINMA’s current supervisory approach does not allow dormant SRO members or shell entities, companies are expected to demonstrate a meaningful operational presence in Switzerland.

To comply with these expectations, applicants should ensure the following minimum substance elements are in place:

  • Appointment of a Swiss-resident director actively involved in governance and oversight.

  • Engagement of a local AML auditor — this is a mandatory requirement under the SRO framework.

  • Designation of a Swiss-based AML Compliance Officer to act as the second line of defence.

  • Establishment of a dedicated office space in Switzerland; shared office solutions are generally discouraged.

  • Employment of at least one Swiss-based staff member as the business becomes operational and scales.

No, VQF SRO members are not subject to a regulatory capital requirement. Unlike banks or licensed financial institutions, VQF members do not need to maintain a capital buffer for regulatory purposes. However, Swiss corporate law requires a minimum share capital to establish a legal entity in Switzerland:

  • Swiss AG (Ltd / SA): Requires a minimum capital of CHF 100,000, with at least CHF 50,000 paid up at the time of incorporation.

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

This corporate capital can typically be used for the company’s operational activities, but certain corporate governance obligations — notably under Article 725 of the Swiss Code of Obligations (CO) — must be respected. These rules become particularly relevant in situations involving capital loss or over-indebtedness, where the board of directors must take specific actions to protect creditors.

No, there are no legal limits on the volume of crypto transfers or the amount of payments and digital assets held in custody (with segregated and individualized wallets) when operating under a VQF licence (i.e., as a member of a FINMA-recognised SRO such as VQF).

Yes, the so-called VQF licence (i.e. SRO membership) allows for the combination of both payment and crypto under the same roof. This means that the roles of a PSP and a VASP may be combined within the same entity.

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

Swiss-based companies operating under Swiss financial regulations are not directly subject to MiCA (Markets in Crypto-Assets Regulation), as it is an EU framework. However, MiCA may become relevant if your firm provides cross-border crypto services or markets digital asset products to clients located within the European Union. In such cases, it is essential for Swiss crypto firms to evaluate whether their activities fall within the regulatory scope of MiCA, and to determine whether they benefit from specific exemptions (such as reverse solicitation) or whether local licensing requirements in EU member states may apply.

No, the offering of derivative products generally triggers a FINMA licence. An SRO membership is not sufficient. 

No, members of a Swiss SRO like VQF cannot benefit from EU passporting rights, as Switzerland is not a member of the European Union. This means that regulatory authorisations granted in Switzerland do not grant automatic access to EU markets. However, this does not prevent Swiss companies from offering cross-border services to EU-based clients. Firms must conduct a careful legal and regulatory analysis in each relevant EU member state, especially when actively marketing services or engaging in business development activities within the EU.

Yes. USDT is not prohibited in Switzerland and can be freely used and offered to clients without issue. In principle, MiCA is not applicable in Switzerland. 

Yes, SRO members may apply for a FINMA licence if their planned activities require one. Once granted, the FINMA licence replaces the existing SRO membership, and the company becomes directly supervised by FINMA for all its regulated activities.

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 provides end-to-end support throughout the VQF membership process (and with other SROs) and beyond. We guide you through every step, ensuring full compliance and efficiency, and connect you with the right partners to meet Swiss substance requirements. We collaborate exclusively with experienced local professionals specialized in this field.
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