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On 22 October 2025, the Swiss Federal Council initiated the public consultation on proposed amendments to the Financial Institutions Act ("FinIA"). The draft legislation aims to strengthen the framework for innovative financial technologies, enhance the attractiveness of the Swiss financial centre, and align domestic regulation with evolving international standards. The consultation process will run until 6 February 2026.
Building on Switzerland's 2018 FinTech licence under the Banking Act ("BankA") and the 2021 distributed-ledger-technology (DLT) reforms, the proposal introduces two new licence categories for a) payment institutions (Zahlungsmittelinstitute) and b) crypto institutions (Krypto-Institute). Both are intended to promote innovation while reinforcing financial stability, market integrity and client protection.
Payment Institutions and Stablecoin Issuance
The new payment institution licence will replace the existing FinTech licence under art. 1b BankA. Payment institutions may accept client funds but must not pay interest or grant loans. Client funds must be segregated from own assets and held either as sight deposits with a bank or in high-quality liquid assets (art. 51i revFinIA).
A key novelty is the explicit authorisation to issue "value-stable crypto-based payment instruments" – that is, stablecoins pegged to a currency. Issuers must publish a whitepaper in accordance with the Financial Services Act ("FinSA"), notify FINMA at least 60 days before initial issuance, and ensure redemption at nominal value at any time (art. 12a, 51l–51m revFinIA).
Reserve assets must remain fully covered, diversified and in the same currency as the redemption claim. In insolvency, these assets are segregated in favour of clients and token holders and excluded from the bankruptcy estate (art. 51q revFiNIA).
If a payment institution is deemed systemically significant, the Swiss National Bank (SNB) may designate it as a "significant payment institution", triggering obligations for stabilisation and resolution planning (art. 51n–51p revFinIA).
Crypto Institutions
The second licence category, crypto institutions, covers service providers that safeguard or trade crypto-assets with trading characteristics (art. 51r et seqq. revFinIA). Such institutions may custody stablecoins and other crypto-assets, execute trades for clients or on own account, and offer staking services.
Crypto institutions must maintain adequate capital, liquidity and risk diversification, ensure segregation and clear allocation of client holdings, and comply with detailed record-keeping duties. Staking requires a separate written agreement and explicit risk disclosure (art. 51z revFinIA).
The regime is modelled on that for securities firms but is less comprehensive, reflecting that crypto institutions do not handle "financial instruments" within the meaning of the FinSA. Certain code of conduct and organisational requirements under the FinSA will nevertheless apply.
Policy Context and Expected Impact
According to the explanatory report, the proposal aims to enhance legal certainty and consumer protection while maintaining a technology-neutral and proportionate framework. It also implements FSB and FATF standards and aligns Switzerland with the EU MiCA Regulation. This might also have benefits for foreign supervised institutions seeking to establish Swiss presences, such as EU Payment Services Providers or E-Money Institutions, for which so far no corresponding licence types existed under Swiss regulation.
For Swiss market participants, the reform establishes a clear supervisory perimeter for stablecoin and crypto-asset services. Existing FinTech licensees are expected to transition to the payment-institution regime. Stablecoin issuers that currently rely on bank guarantees or similar constructs will likely require direct authorisation.
While compliance obligations will increase, the reform is expected to strengthen confidence and competitiveness in Switzerland's digital-asset ecosystem.
The consultation on the FinIA amendments marks a decisive step in integrating stablecoins and other crypto-assets into Switzerland's regulated financial architecture. By combining innovation with proportionate supervision, the proposal reinforces Switzerland's position as a trusted and forward-looking centre for digital finance.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
