Analysis
Crypto-Institutions and Stablecoin Issuers: Switzerland's Planned Licences and FINMA's 6 Crypto Guidance Documents
The Federal Council's 2025 consultation would add two licence categories. Until then, FINMA's guidance sets the supervisory line on staking, stablecoins and custody.
The short version: Switzerland has no stand-alone licence for crypto exchanges or brokers yet. On 22 Oct 2025 the Federal Council proposed two new licence categories, crypto-institutions and payment instrument institutions; the consultation closed on 6 Feb 2026 (Federal Council). Meanwhile, FINMA has published 6 guidance documents on crypto topics since 2017 (FINMA).
The Proposed Licences
The parts of the DLT Act that enable ledger-based securities took effect on 1 Feb 2021; the act was fully in force from 1 Aug 2021, allowing DLT trading facilities and increasing legal certainty in the event of bankruptcy (SIF). On 22 Oct 2025 the Federal Council opened a consultation on amending the Financial Institutions Act to create two licence categories: payment instrument institutions, replacing the FinTech licence and removing its CHF 100 million limit on client deposits, and crypto-institutions for services with cryptocurrencies. The consultation ran until 6 Feb 2026 (Federal Council); the Federal Council said it would submit a dispatch to Parliament in the second half of 2026 at the earliest (SIF fact sheet). The latest release on SIF's DLT page is dated 22 October 2025.
FINMA's Guidance
FINMA guidance explains how FINMA applies existing rules; FINMA says it “does not have legal impact”. The documents whose titles name crypto topics run from initial coin offerings (04/2017) to the custody of cryptobased assets (01/2026, 12 Jan 2026).
| Published | FINMA Guidance | Title (FINMA) |
|---|---|---|
| 12 Jan 2026 | 01/2026 | Custody of cryptobased assets |
| 5 Sep 2025 | 03/2025 | Disclosure of cryptobased assets in banks’ annual financial statements |
| 26 Jul 2024 | 06/2024 | Stablecoins: risks and challenges for issuers of stablecoins and banks providing guarantees |
| 20 Dec 2023 | 08/2023 | Staking |
| 26 Aug 2019 | 02/2019 | Payments on the blockchain |
| 29 Sep 2017 | 04/2017 | Regulatory treatment of initial coin offerings |
Selection by FINMA's own titles (crypto, stablecoins, staking, blockchain, coin offerings). Guidance on wider topics that also touches crypto is not included.
Sources
- Federal Council / SIF release www.sif.admin.ch
- SIF fact sheet www.sif.admin.ch
- FINMA Guidance www.finma.ch