15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the FINMA decision, including banking and payment rails.
Get a payment license in Switzerland.
Switzerland has no EMI licence, and that is the point. The routes that exist are different and clearly drawn: the FINMA fintech licence for deposits up to CHF 100 million, AMLA registration for payment services, and the franc's stability underneath. We map yours.
Updated
No EMI regime - a different map, clearly drawn.
Switzerland is not in the EU or EEA, and it never transposed the e-money directive - there is no Swiss EMI licence, and anyone selling one is selling paper. What exists is a different architecture. The centrepiece is the FINMA fintech licence under Article 1b of the Banking Act: authorisation to accept public deposits up to CHF 100 million - or to hold collective custody of crypto-based assets - on two strict conditions FINMA spells out: the deposits are not invested, and no interest is paid on them. Beneath it, the Banking Ordinance's sandbox tolerates up to CHF 1 million without authorisation, and above it sits the full banking licence. Alongside runs the AMLA layer: payment services and money transmission are financial intermediation, which means affiliation with a recognised self-regulatory organisation - the registration route most Swiss payment businesses actually start with.
Why bother, without an EU passport? Because Switzerland is what it is: the franc's stability, a AAA sovereign, the world's densest private-banking infrastructure, and - in Zug and Zurich - the Crypto Valley cluster where token-adjacent payment models find counsel, banks and precedent nowhere else matches. Cantonal competition prices corporate tax from roughly 12% (Zug) to 21%, VAT runs at 8.1%, and the treaty network passes one hundred. The working structure for EU-facing models is a pair: a Swiss fintech-licensed or SRO-registered entity for CHF and global flows, an EU EMI for the single market. We build both. Realistic end-to-end for the fintech licence: 9-15 months.
No Swiss EMI exists - the real map: FINMA fintech licence (deposits ≤ CHF 100M, no interest, no investment, capital CHF 300k/3%), SRO registration under the AMLA, sandbox ≤ CHF 1M.
No EU passport - the working structure pairs a Swiss entity with an EU EMI. What Switzerland sells: the franc, the AAA, Crypto Valley.
The fintech licence - or the AMLA/SRO route.
Two genuinely different entries: FINMA's Article 1b authorisation for deposit-taking models up to CHF 100 million, or SRO affiliation under the AMLA for payment services without deposits. We fix the route first, then build once.
The Art. 1b fintech licence - or the AMLA/SRO registration route.
Art. 1b Banking Act
The flagship route for e-money-adjacent models: public deposits up to CHF 100 million - or collective crypto custody. Under FINMA authorisation, with no investment of the funds and no interest paid.
The flagship route for e-money-adjacent models: public deposits up to CHF 100 million - or collective crypto custody. Under FINMA authorisation, with no investment of the funds and no interest paid.
- ✓Public deposits ≤ CHF 100 million
- ✓Collective crypto custody in scope
- ✓No investment · no interest - by law
- ✓CHF 300,000 minimum capital · 3% of deposits
- ✓FINMA-supervised, register-published
- ✓Sandbox below - CHF 1M tolerance
Payment services registration
Payment services and money transmission are financial intermediation under the AMLA. The route is affiliation with a recognised SRO, faster and lighter than authorisation, with the fintech licence as the upgrade.
SRO affiliation for payment services; no deposits; weeks not years; upgrade to Art. 1b.
- ✓SRO affiliation - AMLA compliance
- ✓Money transmission and payment services
- ✓No deposit-taking - the boundary
- ✓Weeks-to-months, not years
- ✓Upgrade path to Art. 1b
- ✓FINMA-recognised SROs
Costs and timelines are confirmed for your case before any work begins. FINMA fees follow its ordinance; SRO costs vary by organisation. Capital, substance and audit costs are itemised in your quote.
What the franc buys.
No EU passport, and a set of assets no EU desk can offer. The trade is real, and for the right models it is worth it.
Article 1b created a deposit-taking authorisation below the banking licence. E-money-adjacent models hold client funds at national scale under FINMA supervision, without becoming a bank.Deposit-taking below a bank.
Zug and Zurich concentrate token-payment counsel, banks and licensed precedent like nowhere else. Hybrid models are Tuesday here, not a first impression.Licensed precedent, fluent banks.
Client funds denominated in the world's premier safe-haven currency, in a AAA jurisdiction. A treasury argument that sells itself to certain clients.The treasury argument.
Roughly 12% combined in Zug to ~21% in Geneva. The seat is a genuine pricing decision, and the low end undercuts most of the EU.~12% in Zug - seat decides.
AMLA registration through a recognised SRO starts payment operations in weeks. The staircase to Article 1b is real and well-trodden.Operating in weeks.
Swiss entity for CHF and global flows, EU EMI for the single market. We build the pair as one project rather than pretending one licence does both jobs.Swiss + EU EMI, one project.
How Switzerland differs from EU routes.
A different architecture, compared squarely. No passport - different assets.
| Feature | Switzerland | EU jurisdictions |
|---|---|---|
| Regime | FinTech licence + AMLA - no EMI | EMD2/PSD2 EMI/PI |
| EU passport | None - pair with an EU EMI | EU/EEA on notification |
| Deposit vehicle | Art. 1b - CHF 100M ceiling | E-money issuance |
| Currency | CHF - safe haven | EUR |
| Country | License type | Taxation | Requirements |
|---|---|---|---|
Switzerland | FinTech / SRO (FINMA) | ~12-21% cantonal | No EU passport, CHF stability |
Lithuania | EMI (Bank of Lithuania) | 17% CIT (2026) | CENTROlink, specialised desk |
United Kingdom | EMI (FCA) | 25% CIT · 19% small | No EU passport post-Brexit |
Germany | EMI (BaFin) | ~30-33% effective | German file, dual supervision |
Switzerland
Lithuania
United Kingdom
GermanyRequirements for the FINMA fintech licence.Requirements for the fintech licence.
FINMA authorises against the Banking Act and its ordinances. The craft is a file that reads like the near-bank it describes. The checklist below is what a passing application contains.
Reflects the Banking Act (Art. 1b), the Banking Ordinance and FINMA's published fintech guidance as of 2026.Banking Act Art. 1b + Ordinance + FINMA guidance, as of 2026.
From route map to FINMA authorisation.
Sandbox, SRO, fintech licence or the EU-pairing. We fix the architecture, capital and timeline in writing.Sandbox, SRO, 1b or the pair.
AG formation in the right canton, capital evidence and the resident officers FINMA vets.AG, canton, resident officers.
Business plan, client-fund architecture, AML and IT documentation. With the Article 1b boundary engineered into the product.Boundary engineered, file complete.
Question rounds answered, the audit firm scoped - 9-15 months realistic for the fintech licence; SRO routes far faster.9-15 months; SRO far faster.
The register entry, banking relationships live, and the EU pairing sequenced where the model needs the single market.Register, banks. EU pair sequenced.
The wrong Swiss route wastes a year; the right one is often a pair. Drawing that map correctly is the first thing we do.
Run from our Zug office.

AG or GmbH incorporation, cantonal seat selection and the capital structure FINMA expects. Built for the licence from day one.AG + canton choice, built for the file.
Sandbox, SRO, Article 1b or the full pairing with an EU EMI. The full map drawn before any drafting, because the wrong route wastes a year.The full map before drafting.
Business plan, client-fund architecture, AML pack and IT documentation to FINMA's guidance. Drafted with Swiss counsel and defended through the rounds.To the guidance, defended in rounds.
Resident directors, compliance officer and the regulatory auditor from Zurich's and Zug's deep pools. Real Swiss substance.Zurich/Zug talent, real ops.







Taxation of payment companies in Switzerland.
Cantonal competition does the work: roughly 12% combined in Zug to ~21% in Geneva. With 8.1% VAT and a hundred-treaty network.
Combined federal-cantonal-communal rates run from roughly 11.9% in Zug upward. The seat is a genuine pricing decision we model before incorporation.Zug ~11.9% - seat decides.
Payment and financial services are VAT-exempt; Switzerland's 8.1% standard rate - Europe's lowest. Touches only ordinary supplies.Europe's lowest standard rate.
The 35% withholding is a compliance mechanism, not a cost: treaties and participation rules refund or eliminate it for properly structured holders.Treaty-refunded for holders.
Profit, capital and client funds in CHF remove euro-cycle exposure. A treasury property some models price above any tax point.Treasury property, priced in.
Zug's administration has taxed token businesses for a decade. Hybrid payment models find settled practice, not first impressions.Settled, not first-impression.
One of the world's deepest treaty networks. Group structures above the Swiss entity model cleanly.World-scale network.
*Figures as of 2026 per the Federal Tax Administration and cantonal schedules. The seat decides the rate. We model it before you commit.
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Builds the application itself: Swiss AG, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised institution.
Active across our channels.
Launch your payment project in Switzerland with expert support.
Full-service assistance - from AG formation to the FINMA fintech licence or SRO affiliation, and the EU pairing where your model needs it.
Get a consultation →Is Switzerland the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
The Swiss payment routes: frequent questions.
Is there an EMI licence in Switzerland?+
No - Switzerland never transposed the EU e-money directive, and no Swiss EMI licence exists. The genuine routes are the FINMA fintech licence (Article 1b Banking Act), AMLA/SRO registration for payment services, the sandbox below CHF 1 million, and the banking licence above. Anyone selling a 'Swiss EMI' is selling paper.
What does the fintech licence actually allow?+
Acceptance of public deposits up to CHF 100 million - or collective custody of crypto-based assets - under FINMA authorisation, on two statutory conditions: the funds are not invested, and no interest is paid. For e-money-adjacent models it is the Swiss vehicle.
What capital does it require?+
CHF 300,000 minimum or 3% of public deposits, whichever is higher, fully paid in - scaling with the float exactly as the risk does.
What is the SRO route?+
Payment services and money transmission are financial intermediation under the AMLA, requiring affiliation with a FINMA-recognised self-regulatory organisation - a registration-grade route that starts operations in weeks and upgrades to Article 1b when deposits enter the model.
Does a Swiss authorisation passport into the EU?+
No - Switzerland is outside the EU/EEA and there is no passporting. EU-facing models pair a Swiss entity for CHF and global flows with an EU EMI for the single market; we build the pair as one project.
How long does the fintech licence take?+
Realistically 9-15 months end to end including FINMA's rounds and the audit-firm scoping; SRO affiliation runs in weeks to months. The route map decides the timeline, which is why we draw it first.
What substance is expected?+
A Swiss AG effectively managed in Switzerland, resident directors, a compliance function reporting to MROS, the regulatory auditor appointed, and client-fund architecture FINMA can verify - a brass plate survives nothing here.
How are payment companies taxed?+
By canton: roughly 12% combined in Zug to ~21% in Geneva, VAT-exempt payment services under an 8.1% standard rate, and 35% dividend withholding that treaties refund for structured holders.
Why do crypto-payment models pick Switzerland?+
Crypto Valley: a decade of licensed precedent, banks that onboard token businesses, counsel that has drafted these files before - plus the fintech licence's explicit crypto-custody scope. Hybrid models get settled practice instead of first impressions.
Why Switzerland rather than an EU desk?+
Different products. EU desks sell the passport; Switzerland sells the franc, the AAA, Crypto Valley and the CHF 100M deposit vehicle. Global-facing and treasury-sensitive models take the pair - Swiss entity plus EU EMI, and get both.
Swiss EMI?+
Doesn't exist. FinTech licence + SRO are real.
FinTech licence?+
Deposits ≤ CHF 100M; no interest, no investment.
Capital?+
CHF 300k or 3% of deposits.
SRO route?+
AMLA registration - weeks, no deposits.
EU passport?+
None - pair with an EU EMI.
How long?+
9-15 months (1b); SRO much faster.
Substance?+
Resident directors, auditor, real ops.
Taxes?+
~12-21% by canton; VAT 8.1%.
Crypto models?+
Crypto Valley precedent - yes.
Vs EU desks?+
They sell the passport; CH sells the franc.
Founders who wanted it done right.
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.Free legal opinion: which Swiss route fits your project and what it will cost.
Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Swiss Financial Market Supervisory Authority (FINMA) or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.