Fintech & payments regulation in Switzerland (2026)

Legal framework

Banking Act (BankG) / Banking Ordinance (BankV), FinTech licence issued by FINMA; Financial Institutions Act (FinIA/FINIG) reform (consultation 2025-2026); SIC instant-payment rail operated by SIX under Swiss National Bank oversight

Key points: digital payments & fintech in Switzerland

1. 01FinTech Licence (Banking Act)

   Since 1 January 2019, FINMA may grant a FinTech licence to entities that accept public deposits of up to CHF 100 million (or crypto-assets), provided the funds are not invested and no interest is paid. Capital and governance requirements are lighter than a full banking licence. Entities below CHF 1 million fall under the sandbox and need no licence at all.

   finma.ch finma.ch

2. 02Regulatory Sandbox

   In force since August 2017 and amended April 2019, the sandbox allows acceptance of public deposits up to CHF 1 million without any banking or FinTech licence, subject to AML compliance and affiliation to a self-regulatory organisation. It is intended purely as an innovation testing space.

   finma.ch finma.ch

3. 03Proposed FinIA Reform, Payment & Crypto Institution Licences

   On 22 October 2025 the Federal Council opened a consultation (deadline 6 February 2026) to amend the Financial Institutions Act. The proposal creates two new licence categories, a payment institution licence and a crypto institution licence, designed to replace the existing FinTech licence, which authorities consider insufficiently tailored to payment-service and digital-asset business models. Entry into force is expected late 2026 or early 2027.

   admin.ch loyensloeff.com caplaw.ch

4. 04Open Banking / Open Finance

   Switzerland's open-banking model is entirely voluntary and industry-driven; there is no legal obligation for banks to share customer data with third-party providers. The SIX bLink platform (live since 2020) provides standardised APIs. On 25 November 2025, multibanking for retail clients launched with 30 banks supplying data and eight banks plus two fintechs aggregating it. In December 2025 the Federal Council confirmed no regulatory mandate for open-data interfaces is planned for the near term.

   sif.admin.ch six-group.com admin.ch

5. 05Instant Payments, SIC5 Rail

   SIX and the Swiss National Bank launched the SIC5 infrastructure (new-generation Swiss Interbank Clearing) with an instant-payment service in November 2023. Since 20 August 2024, over 100 financial institutions covering approximately 95% of Swiss retail payment volumes must accept incoming instant payments; all remaining SIC participants must comply by November 2026 at the latest. The SNB decision to make acceptance mandatory dates to June 2021.

   six-group.com snb.ch six-group.com

6. 06BNPL Regulation

   Buy-now-pay-later products in Switzerland are governed by the existing Consumer Credit Act (KKG), which covers loans between CHF 500 and CHF 80,000; loans repayable within three months are statutorily exempt. Switzerland is not an EU member and is not bound by the EU Consumer Credit Directive II (CCD II). No Switzerland-specific BNPL reform has been proposed as of mid-2026.

   krediteschweiz.ch globallegalinsights.com

Timeline of decisions

1. 12 Jan 2026Guidance · official
   FINMA Guidance on Custody Risks for Crypto-Based Assets

   FINMA published Guidance 01/2026 setting out supervisory expectations for institutions holding crypto-based assets on behalf of clients, addressing segregation, safekeeping obligations, and operational risks. Signals that crypto custody is now treated as a mainstream supervisory concern on par with traditional asset safekeeping.

   FINMA

2. 22 Oct 2025Law · official
   Federal Council Consults on Replacing FinTech Licence with Payment Institution and Crypto Institution Categories

   The Federal Council opened a consultation on FinIA amendments proposing to abolish the 2019 FinTech banking licence and introduce two FINMA-supervised licence categories: Payment Instrument Institutions (stablecoin issuers / payment firms, no CHF 100 m cap) and Crypto Institutions (lighter-touch than securities firms). Consultation closed 6 February 2026; implementation expected late 2026, early 2027.

   State Secretariat for International Finance (SIF)

3. 21 Aug 2024Decision · official
   Mandatory Instant Payment Reception Launched, Large Swiss Banks Obligated

   SIX and the Swiss National Bank formally launched the instant-payment service commercially; all banks that processed more than 500,000 incoming SIC transactions in 2020 became obligated to accept incoming instant payments 24/7. Unlike EU peers, Switzerland opted for regulatory compulsion from day one rather than voluntary adoption; remaining institutions must comply by end-2026.

   SIX Group

4. 17 Nov 2023Decision · official
   SIC5 Platform Goes Live, Technical Foundation for Swiss Instant Payments

   SIX and the Swiss National Bank launched the fifth generation of the Swiss Interbank Clearing (SIC5) system, replacing legacy infrastructure and enabling round-the-clock real-time gross settlement. SIC5 was the prerequisite for the August 2024 mandatory instant-payment rollout and represents the most significant overhaul of Swiss payment infrastructure in decades.

   Swiss National Bank (SNB)

5. 1 Aug 2021Law · official
   DLT Act Fully In Force, Ledger-Based Securities and DLT Trading Facility Licence

   The Federal Act on the Adaptation of Legislation to DLT came fully into force, introducing ledger-based securities (Registerwertrecht) in the Code of Obligations, a new DLT Trading Facility licence category under FMIA, and bankruptcy-law protection for segregated crypto assets. Switzerland became one of the first countries with a comprehensive statutory framework for tokenised financial instruments.

   Swiss Federal Council

6. 1 Jan 2020Law · official
   Financial Services Act (FinSA) and Financial Institutions Act (FinIA) Enter into Force

   FinSA (SR 950.1) and FinIA (SR 954.1) together with their implementing ordinances took effect, creating a cross-sectoral conduct-of-business rulebook for all financial service providers and a unified licensing hierarchy for financial institutions, including fintech and asset-management firms, broadly paralleling MiFID II and PRIIPS but with Swiss-specific adaptations.

   Swiss Federal Chancellery (Fedlex)

7. 1 Jan 2019Law · official
   FinTech Banking Licence Enters into Force

   The Banking Act amendment creating a 'light' FinTech licence category took effect, allowing non-bank entities to accept public deposits up to CHF 100 million without a full banking licence, provided deposits are not reinvested and bear no interest. This was Switzerland's first dedicated prudential licence for payment and fintech firms and FINMA adapted its circulars accordingly by 1 July 2019.

   FINMA

8. 1 Aug 2017Law · official
   FinTech Sandbox and Extended Settlement Holding Period Introduced via Banking Ordinance

   A Federal Council amendment to the Banking Ordinance (adopted 5 July 2017, in force 1 August 2017) created Switzerland's first fintech regulatory sandbox, allowing firms to accept public deposits from more than 20 customers up to CHF 1 million without a banking licence, and extended the settlement holding period for third-party funds from 7 to 60 days, reducing barriers to entry for payment and crowdfunding platforms.

   Swiss Federal Council

Sources

1. 1.finma.ch/en/authorisation/fintech/fintech-bewilligung/
2. 2.finma.ch/en/authorisation/fintech/
3. 3.finma.ch/en/news/2019/03/20190315-mm-fintech/
4. 4.admin.ch/en/newnsb/x4TMWQ1SWofNoFx7XyHhY
5. 5.sif.admin.ch/en/open-finance-en
6. 6.six-group.com/en/newsroom/media-releases/2025/20251125-multibanking-launch.html
7. 7.admin.ch/gov/en/start/documentation/media-releases.msg-id-101491.html
8. 8.six-group.com/en/products-services/banking-services/billing-and-payments/instant-pa
9. 9.snb.ch/en/the-snb/mandates-goals/payment-transactions/swiss-interbank-cleari
10. 10.six-group.com/en/newsroom/media-releases/2024/20240116-six-instant-payment.html
11. 11.loyensloeff.com/insights/news--events/news/swiss-federal-council-proposes-finia-amend
12. 12.caplaw.ch/2026/can-the-federal-councils-proposals-reinvigorate-the-swiss-fintec
13. 13.krediteschweiz.ch/en/consumer-credit-act
14. 14.globallegalinsights.com/practice-areas/fintech-laws-and-regulations/switzerland/