Which Switzerland Crypto License Does a Crypto Exchange Need Today?
There is no single Switzerland crypto license for exchanges. Swiss law looks at what your exchange actually does. Does it hold clients’ money? Does it hold their crypto? Does it trade securities in token form? Each answer points to a different route, from a simple membership to a full banking licence.
The rules are also about to change. On 22 October 2025, the Federal Council opened a consultation on a new licence for "crypto institutions". Law firm Loyens & Loeff, reading the draft, says its scope "also encompasses cryptocurrency exchange services". So an exchange planning for 2027 and beyond needs to understand both the current routes and the new one.
First, describe your exchange in plain words
Before you look at any licence, answer four questions.
- What do users trade? Payment tokens such as bitcoin, or tokens that act like shares or bonds?
- Do users trade with you, or with each other through your order book?
- Do you hold users’ crypto or money between trades?
- Do you pay interest, lend or invest what users leave with you?
Swiss law does not care what you call your business. It cares what the business does. Your four answers decide your route.
Route 1: SRO membership, for a simple exchange
Under the Swiss Anti-Money Laundering Act, a firm that handles other people’s assets as a business is a "financial intermediary". FINMA explains that such firms "must become members of a self-regulatory organisation (SRO)" to meet their anti-money-laundering duties, unless FINMA supervises them directly.
For many exchanges of payment tokens, this is the starting point. A broker that buys and sells bitcoin for clients, and sends it straight to their own wallets, usually works under an SRO. The SRO checks its client checks, its screening of crypto transfers and its reporting.
SRO membership covers anti-money-laundering duties. It is not a licence to take deposits, lend or run a securities market. The detail of this route is on the Switzerland SRO membership page.
Route 2: the FinTech licence, when you hold client assets
Many exchanges hold users’ money or crypto between trades. That can change the answer.
The key question is whether you are taking "public deposits". That is the business Swiss banking law controls.
Swiss francs that clients leave with you, and that you owe back to them, are the clearest case of a deposit. Crypto can be a deposit too. It depends on how you hold it. Crypto kept apart for each named client, which the client still owns and which stays outside your company if it fails, is usually not a deposit. That kind of custody often stays on the anti-money-laundering route. Crypto mixed in one shared pool that you can use as you like is closer to a deposit.
FINMA’s FinTech licence covers the deposit case up to a limit. FINMA says it "allows institutions to accept public deposits of up to CHF 100 million or cryptobased assets, provided that these are not invested and no interest is paid on them". The CHF 100 million limit applies in total, whether the deposits are francs or crypto. Above that limit, the exchange needs a banking licence.
How you hold each asset decides the route. This is exactly the kind of point to settle with a Swiss lawyer before launch.
Route 3: a banking licence, for interest and investing deposits
If your exchange pays interest on client deposits, or lends or invests those deposits, the FinTech licence no longer fits. The same applies once deposits pass CHF 100 million. These cases need a full banking licence from FINMA. Lending your own money or your own coins is a different question from lending clients’ deposits. It is the heaviest route, with strict rules on capital, staff and risk control. Very few new crypto exchanges start here.
Route 4: a DLT trading facility, for tokenised securities
Some platforms trade tokens that are really securities, such as tokenised shares or bonds. FINMA says a DLT trading facility licence "allows for multilateral trading of DLT securities". DLT means distributed ledger technology, the systems that blockchains run on.
This licence is not for a normal bitcoin exchange. It is for a market in securities issued on a blockchain. It is a full FINMA authorisation under the Financial Market Infrastructure Act.
Each Switzerland crypto license route, side by side
| What your exchange does | Usual route today |
|---|---|
| Buys and sells payment tokens for clients, no client balances held | SRO membership under AML law |
| Keeps each client’s crypto apart, owned by the client | Usually SRO membership, but check with a lawyer |
| Holds client francs, or pooled crypto, up to CHF 100 million, not invested, no interest | FinTech licence from FINMA |
| Pays interest, lends or invests client deposits, or holds over CHF 100 million | Banking licence from FINMA |
| Runs a market in tokenised securities | DLT trading facility licence |
This is a simplified guide. Your own facts, and how your contracts are written, decide the real answer.
What the FinIA reform changes for exchanges
The draft amendment to the Financial Institutions Act (FinIA) adds a licence for crypto institutions. Loyens & Loeff describe its scope as custody of crypto-based assets, "client trading and short-term proprietary trading which also encompasses cryptocurrency exchange services".
In practice, that means many exchanges that run under an SRO today would move to direct FINMA supervision. Firms that already do this work under an SRO would get one year from the start of the law to apply. They could keep working while the application is pending, as long as they stay in an SRO. Our guide on the FinIA reform and Switzerland SRO membership covers that transition.
No start date has been set. The consultation closed on 6 February 2026, and Parliament still has to debate the proposal.
One exchange, three stages
Here is how the route can change as one exchange grows.
At the start, the exchange lets users buy bitcoin with Swiss francs. It sends the bitcoin straight to each user’s own wallet. It holds nothing overnight. It joins an SRO and runs its anti-money-laundering checks.
A year later, users ask to keep a balance on the exchange so they can trade faster. Now the exchange holds their francs and their bitcoin. It does not lend them or pay interest. This is the point to check whether the FinTech licence is needed. The team asks a Swiss lawyer before the feature goes live, not after.
Two years in, the exchange wants to offer interest on balances. Paying interest on client deposits takes it outside the FinTech licence, even if the interest comes from its own money. It now needs a banking licence. The team either drops the idea or plans for that much bigger licence.
The same company, with the same name and the same users, can sit under three different routes. The trigger each time is a new feature. So build a habit: before any new feature, ask whether it changes what you hold or what you do with it.
Mistakes exchanges make in Switzerland
The first is starting under an SRO and then adding client balances without checking the rules again. The route that fitted on day one may not fit after a new feature.
The second is treating a token as a payment token without checking. If it behaves like a share, the securities rules apply.
The third is underestimating banking. Even with the right authorisation, a Swiss bank must agree to hold the exchange’s money. Start that conversation early.
Where to go next
If you are setting up from Asia, how Hong Kong founders get a Switzerland crypto license walks through the company, director and bank steps. If speed matters, look at Swiss companies with SRO membership for sale.
Frequently asked questions
Do I need a licence to run a crypto exchange in Switzerland?
Not always a FINMA licence. Every crypto exchange needs anti-money-laundering supervision, usually through SRO membership. A FINMA licence comes in when you take public deposits or trade tokenised securities.
Is SRO membership enough for a crypto exchange in Switzerland?
It can be for an exchange that takes no public deposits and does not trade securities. If you hold client francs or pooled crypto, you may need a FinTech licence.
What does the Swiss FinTech licence allow?
It lets a firm accept public deposits, in francs or crypto, up to CHF 100 million in total. The deposits must not be invested, and no interest may be paid on them.
What is a DLT trading facility in Switzerland?
It is a FINMA licence for multilateral trading of DLT securities, meaning securities issued on a blockchain. It is not needed for a normal bitcoin exchange.
Will the FinIA reform create a crypto exchange licence?
The draft creates a crypto institution licence whose scope includes cryptocurrency exchange services. It is not in force, and no start date has been set.
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*Sources: FINMA pages on self-regulatory organisations, the FinTech licence and DLT trading facilities; State Secretariat for International Finance press release of 22 October 2025; Loyens & Loeff, "FinIA reform: new licences for payment and crypto-institutions", 27 October 2025.*