Q: When does a payment business need a FinTech or banking licence?

When it holds public deposits: money on customers’ behalf that is not segregated and individually attributable to them. A pure payment intermediary that only moves funds and does not hold them as deposits may need AML affiliation but not a deposit licence. But a model that holds customer balances (a wallet, a stored-value account, float held over time) can cross into deposit-taking, bringing the FinTech licence (up to CHF 100 million, not invested) or, beyond that, a banking licence. The dividing line is technical: segregation, attribution and how long funds are held all matter. We assess where the fund flow sits and whether a deposit licence is triggered, because getting this wrong is the classic payment-business error.

Q: Do I need SRO membership for a payment business?

Usually yes, under today’s rules. A payment, e-money or money-transmitting business is typically a financial intermediary subject to the Anti-Money Laundering Act, and where it is not otherwise prudentially supervised, that means affiliation with a Self-Regulatory Organisation, which supervises its AML compliance. SRO membership is often the fastest route to operating, and for many payment models it is the core authorisation, alongside whatever deposit-licence question the fund flow raises. Under the 2027 reform, payment-instrument institutions would move to direct FINMA supervision instead. We arrange the SRO affiliation and the AML framework, and position the business for the supervisory shift ahead.

Question 1

Is there a dedicated payment institution licence in Switzerland today?

Accepted Answer

Not in the EU sense, yet. Switzerland does not currently have a single, dedicated payment-institution or e-money licence equivalent to the EU&rsquo;s PSD2 framework. Instead, a payment, e-money or money-transmitting business is regulated today through a combination of routes depending on what it does: anti-money-laundering affiliation with a Self-Regulatory Organisation as a financial intermediary, and, where it holds public funds, potentially the FinTech licence or even a banking licence. That is set to change: the proposed 2027 reform introduces a dedicated Payment Instrument Institution licence under direct FINMA supervision. We map your model to the right combination of routes today, with the coming licence in view.

Question 2

How is a payment business regulated in Switzerland now?

Accepted Answer

Through whichever regime its activity triggers, often more than one. Providing payment services (transferring funds, issuing means of payment, money transmission) generally makes you a financial intermediary with anti-money-laundering duties under the Anti-Money Laundering Act, requiring affiliation with a Self-Regulatory Organisation. If the model also involves holding public funds on customers&rsquo; behalf, that can bring it within the deposit concept and so the FinTech or banking licence. E-money and stored-value models turn on how the balances are held. The right answer is rarely a single box; it is a combination determined by the precise flow of funds. We resolve that mapping before you build.

Question 3

When does a payment business need a FinTech or banking licence?

Accepted Answer

When it holds public deposits: money on customers&rsquo; behalf that is not segregated and individually attributable to them. A pure payment intermediary that only moves funds and does not hold them as deposits may need AML affiliation but not a deposit licence. But a model that holds customer balances (a wallet, a stored-value account, float held over time) can cross into deposit-taking, bringing the FinTech licence (up to CHF 100 million, not invested) or, beyond that, a banking licence. The dividing line is technical: segregation, attribution and how long funds are held all matter. We assess where the fund flow sits and whether a deposit licence is triggered, because getting this wrong is the classic payment-business error.

Question 4

What is the 2027 Payment Instrument Institution licence?

Accepted Answer

A new, dedicated licence the Federal Council has proposed to replace the FinTech licence and regulate payment and e-money businesses directly. As proposed in the consultation opened in October 2025, the Payment Instrument Institution licence would put payment-instrument and e-money businesses under direct FINMA supervision, remove the CHF 100 million deposit cap that constrains the FinTech licence, require segregation of client funds, and bring stablecoin and stored-value payment models into a clearer framework. The reform is expected to take effect around late 2026 or 2027. For a payment business planning now, the right strategy depends on whether to build for today&rsquo;s routes or position for the new licence. We advise on that timing.

Question 5

Do I need SRO membership for a payment business?

Accepted Answer

Usually yes, under today&rsquo;s rules. A payment, e-money or money-transmitting business is typically a financial intermediary subject to the Anti-Money Laundering Act, and where it is not otherwise prudentially supervised, that means affiliation with a Self-Regulatory Organisation, which supervises its AML compliance. SRO membership is often the fastest route to operating, and for many payment models it is the core authorisation, alongside whatever deposit-licence question the fund flow raises. Under the 2027 reform, payment-instrument institutions would move to direct FINMA supervision instead. We arrange the SRO affiliation and the AML framework, and position the business for the supervisory shift ahead.

Question 6

How are stablecoin and crypto payment models treated?

Accepted Answer

With particular care, because they sit across several regimes and the rules are changing. A stablecoin or crypto-based payment model can engage the deposit concept (FinTech or banking licence), the collective-investment rules, AML duties, and, depending on structure, a FINMA ruling on the token’s classification. The proposed 2027 reform would create a clearer route, allowing payment-instrument institutions to issue fully-backed, single-currency “stable payment crypto-assets” under defined conditions. Because the treatment is both technical and in transition, a crypto payment business should confirm its regulatory status before launch. We assess it across the regimes and coordinate with our crypto desk and token rulings work.

Question 7

Can a foreign payment provider operate in or into Switzerland?

Accepted Answer

It depends on how and to whom. A foreign payment provider serving Swiss customers may bring itself within Swiss AML and licensing rules depending on the degree to which it directs activity into Switzerland and holds funds. Establishing a Swiss entity with real substance is the route to operating from Switzerland; serving Swiss clients cross-border raises questions of which Swiss rules attach. The analysis is fact-specific and turns on the fund flow, the customer base and the marketing. We assess the cross-border position, and where a Swiss presence is the answer, incorporate the entity, arrange the SRO affiliation and any deposit licence, and build the AML framework as one project.

Question 8

How long does it take to authorise a payment business?

Accepted Answer

SRO affiliation is often the fastest authorisation in Swiss financial regulation (a matter of a few months with a complete file), while a deposit licence, if the model needs one, takes considerably longer. Because most payment businesses are authorised today through a combination of SRO membership and, where required, a FinTech or banking licence, the timeline depends on which elements apply. A pure AML-affiliation model moves quickly; a deposit-holding model runs on the longer FinTech or banking timetable. The variable, as always, is the completeness of the file. We scope which elements your model needs and build them in the right order to reach market efficiently.

Question 9

What ongoing obligations apply to a payment business?

Accepted Answer

Principally the anti-money-laundering ones, plus whatever a deposit licence adds. An AML-affiliated payment business must maintain its AML framework (risk analysis, KYC and onboarding, transaction monitoring, an AML officer and reporting of suspicions) and undergo the SRO&rsquo;s periodic audit. A model that also holds a FinTech or banking licence carries the prudential obligations on top: capital, reporting and a regulatory audit. Payment businesses are AML-intensive by nature, given the transaction volumes, so the monitoring function has to be genuinely operational. We can run the ongoing AML and compliance function and manage the audit cycle after launch.

Question 10

Should I build for today's rules or wait for the 2027 licence?

Accepted Answer

It depends on your timeline and model, and it is exactly the question to resolve before committing. A business that needs to operate now will build on today&rsquo;s routes (SRO affiliation and, where required, a deposit licence) while keeping the coming Payment Instrument Institution regime in view, since it will reshape how payment businesses are supervised and may offer a better fit. A business with a longer runway, or one whose model depends on issuing stablecoins at scale, may be better positioned to build for the new licence. There is no single right answer; there is a right answer for your facts and timeline. We give you that assessment rather than a default.

Question 11

Can Goldblum authorise my payment or e-money business?

Accepted Answer

Yes. We map your payment, e-money or money-transmission model to the right combination of Swiss routes today (SRO affiliation for AML, and, where the fund flow triggers it, the FinTech or banking licence), incorporate the Swiss entity, build the AML and any prudential framework, and carry the authorisations to completion. We assess the deposit-taking and stablecoin questions that catch payment businesses, and we position you for the 2027 Payment Instrument Institution licence so today&rsquo;s build is not undone by the reform. After launch we can run the ongoing AML and compliance function. The value is getting a fast-moving, AML-intensive business correctly authorised the first time.

Swiss payment &
e-money licence

Authorisation for payment businesses.

How payment businesses are authorised in Switzerland

Who this is for

Where it fits

Payment models: which route, and none

Providing payment services on a commercial basis

From mapping to market

Fund-flow mapping

Entity & structure

AML & compliance framework

Authorisation

Go-live & audit cycle

What it costs

What authorisation requires

The deposit question is where payment businesses go wrong

How we run the payment authorisation

Recognised by IFLR1000

The deposit question settled

Built for the reform

Next in this practice

SRO membership

Banking & FinTech licence

Stablecoin & token rulings