Is SRO membership the same as a FINMA license?

No, SRO members are not directly licensed by FINMA, but are supervised through an SRO (e.g., VQF or SO-FIT) that is itself monitored by FINMA.

Can I accept deposits from the public?

Yes, within sandbox limits: Up to CHF 1m (general sandbox limit). Unlimited if structured under specific exceptions (e.g., segregated wallets, institutional clients, 60-day processing, bank guarantee).

Can I provide custody services?

Yes. Segregated wallets → unlimited amount. Omnibus wallets → limited to CHF 1m total.

Are security tokens included?

No, securities and derivatives are excluded and require separate licensing.

Can SRO Regulated company open Swiss bank accounts easily?

It's possible, but banks will still run their own due diligence (business model, source of funds, jurisdictions, expected volumes, aml setup), and approval is not automatic.

How long does the SRO application process take?

Indicative timeline: Company setup & structuring ~1 month, SRO review 3-4 months, Operational implementation ~1 month.

What is the difference between sandbox, fintech license, and banking license?

Sandbox: CHF 1m deposits. Fintech license: up to CHF 100m. Banking license: unlimited deposits + lending permitted.

Swiss SRO Membership (VASP / Financial Intermediary)

A pragmatic Swiss AML-supervised setup for crypto/fiat payment and exchange, brokerage, and credit businesses via membership in a FINMA-authorized SRO

From scratch

From CHF 35,000

Timeline

From 3 months

Ready made

From EUR 195,000

On this page

Quick facts

Regulator / authority

FINMA as a general regulator and VQF, PolyReg, SO-FIT, OAD-FCT, and ARIF as Swiss self-regulatory organizations (SRO) recognized by FINMA

Coverage

Fiat currency payment services, such as payment processing. Currency conversion between fiat and crypto, fiat and fiat, and crypto and fiat. Cryptocurrency custody. Crypto services, such as asset management, trading, and broking. Issuance of cards. Services for stablecoins. Issuance of tokens. Taking deposits from the public up to CHF 1 million. Operations for credit and loans.

Best for

The best solution for businesses that work in the EEA zone and need a multilicensed solution for crypto, brokerage, payments, and credits

Local presence

Required (Swiss entity)

Substance level

Medium (the company should have a local address, the director should be a local with the necessary qualifications, and a local qualified compliance officer should be hired)

Banking friendliness

Medium

Who this is for

Best fit

Want Swiss AML supervision for crypto and fiat services
Run exchange / on-off ramps (fiat<->crypto, crypto<->crypto, fiat<->fiat)
Process payments or transfers for clients
Need custody (segregated; omnibus within limits)
Plan cards / PSP roles via partners

Prefer a pragmatic regime with outsourcing options
Don't focus on securities / security tokens / derivatives
Do credit and loan operations
Deal in brokerage/ trading, asset management

What you can do (scope)

Offering fiat and crypto payment services (payment processing, payment facilitation, fund/crypto transfers, accepting or assisting in the transfer of third-party assets, electronic transfers)
Cryptocurrency custody - with omnibus wallet (limited to CHF 1m in total) and segregated wallet (unlimited amount and period)
Providing cryptocurrency services (issuing a commodity-backed token, issuing a 1:1 fiat-backed stablecoin to fully identified holders (with bank guarantee), conducting an ICO, STO, or ISPO, etc.)
Card Issuance (credit and debit cards, payment instruments, and payment service provider management and issuance)
Taking deposits from the general public (up to CHF 1 million, with the possibility of an unlimited amount if they come from institutional investors with professional treasury management; additional restrictions may apply)
Managing a fiat/crypto exchange (CEX/FX), including swapping fiat <-> fiat, swapping crypto <-> crypto, and trading fiat & crypto on/off ramp
Brokerage/trading, asset management (including cryptocurrency trading, currency trading, precious metals trading, commodities trading, and cryptocurrency market maker)
Credit and lending activities (lease, business loans, mortgages, and consumer credit (further permission may be needed))

Requirements overview

Company & presence

Requires 1 director or board member with single-signature authority based in Switzerland. Minimum one board member can be based in Switzerland or abroad. 1 AML officer must be based in Switzerland. Shareholders may be domiciled abroad.

Key persons / governance

1 Swiss-based director, 1 board member (Swiss-based or abroad), and 1 AML officer based in Switzerland.

Capital / safeguarding / bonds

For a Swiss GmbH (Sàrl), minimum share capital is CHF 20,000, fully paid in at incorporation. For a Swiss AG (SA), minimum share capital is CHF 100,000, with at least CHF 50,000 paid in (or 20%, but not less than CHF 50,000). Capital can be injected into crypto, and capital can be used for daily expenses.

AML/CTF baseline expectations

Requires a business plan, internal AML/CTF policy, compliance manual, and risk assessment / risk matrix.

Reporting / audits

Suspicious Activity Reporting (SAR) to MROS is mandatory when there are reasonable grounds to suspect money laundering/terrorist financing, filed using official forms. Audit frequency is risk-based, set by SROs, with periodic audits (every 1-3 years) and more frequent audits for higher-risk models. External audit firm and report to SRO: independent audit firm checks AMLA and SRO rules, submits formal audit report. Practical governance routine: yearly compliance plan, staff AML training log, periodic file reviews, and documented decisions on high-risk clients/PEPs/sanctions hits.

Process (end-to-end steps)

Step 1: Eligibility + scope mapping

Confirmation that SRO membership is suitable for your business plans, explanations of limitations of SRO-regulated asset management companies.

Step 2: Entity setup / structuring

Set up a Swiss company, inject share capital, Swiss domicile, and interviews with the Swiss-based team.

Step 3: Business documentation preparation, appointment of staff

Preparation of internal AML/CTF policy/compliance manual, business plan, hiring of AML officer, and appointment of AML auditor.

Step 4: Submission to SRO

SRO membership application support; the regulator starts review of the application.

Step 5: Follow-ups & clarifications

Handle SRO-related questions from the regulator and adjust documents.

Step 6: Go-live readiness

Operational implementation (compliance & IT tools) and go-live; note: members are expected to start activities within 2 years after acceptance and build substance after go-live.