Swiss Payment Institution Licence: What Replaces the FinTech Licence
Switzerland is replacing the FinTech licence (Art. 1b Banking Act) with a new licence category: the payment institution («Zahlungsmittelinstitut») under the Financial Institutions Act. The consultation closed in February 2026, and the new law will most likely enter into force in 2027 at the earliest.
Deposit Limit
Abolished
The reform removes the CHF 100 million cap on client funds, so payment institutions can finally scale.
Client Protection
Segregated
Institutions must segregate client funds, which keeps them out of the bankruptcy estate.
New Scope
Stablecoins
Payment institutions may issue and hold Swiss stablecoins and provide payment services.
FinTech Licence vs. Payment Institution — What Changes
The new category keeps the core of the FinTech licence: accepting non-interest-bearing client funds without a full banking licence. Nevertheless, three things change substantially.
First, growth: the CHF 100 million limit disappears, removing the ceiling that forced successful FinTechs toward a banking licence. Second, client protection: client funds must be held so they can be segregated in insolvency — a genuine upgrade over today’s regime, where deposits are neither privileged nor insured. Third, scope: the new licence explicitly covers issuing Swiss stablecoins and providing payment services.
However, some things do not change: only banks may run interest-bearing deposit business, and FINMA remains the licensing authority. In addition, the reform introduces a separate «crypto institution» licence for crypto-asset services — a distinct category with its own requirements.
Who Is Affected
Three groups should prepare now.
Current Art. 1b licence holders will be transitioned into the new category and should review capital, custody and disclosure arrangements against the draft. Founders planning a FinTech licence application should design their governance and documentation so it maps onto the future regime — today’s Swiss FinTech licence requirements largely carry over, and applications prepared now will live under the new law. And payment providers operating without a licence today should assess whether the new perimeter captures their model; the consultation debate suggests some previously unregulated payment services may become licensable.
How to Prepare
- Map your business model against the draft: client funds, stablecoins, payment services
- Review fund-custody arrangements against the segregation requirement
- Align governance and substance with FINMA’s established expectations — these carry over
- Plan capital for growth beyond CHF 100 million if relevant
- Monitor the parliamentary process; final rules may differ from the draft
Frequently Asked Questions
When does the new payment institution licence enter into force?
The consultation ended in February 2026. After evaluation and parliamentary debate, the new rules will most likely apply from 2027 at the earliest.
Do existing FinTech licence holders lose their licence?
No. Lawmakers plan to transition existing Art. 1b institutions into the new category, and the final legislation will then set the details.
Can I still apply for a FinTech licence now?
Yes. Art. 1b remains in force until the new law applies — and an application built on solid governance will transition cleanly.
Shaping the Reform, Not Just Watching It
FinTech Werkstatt is aligned with the Swiss Fintech Alliance (SFA), which has submitted a detailed position paper on the SIF consultation, built on the practical experience of licensed FinTechs and active applicants.
The SFA welcomes the reform — including the abolition of the CHF 100 million threshold — while calling for targeted improvements: statutory deadlines for FINMA licensing decisions, risk-based capital and proportionate group supervision, practical stablecoin rules, and transitional provisions for pending applications. Its guiding concern: without EU passporting, Switzerland’s framework must offer clear advantages over the EU and the UK.
Through this engagement, we follow the reform from inside the industry dialogue — so our clients prepare for the rules as they take shape, not after they are final.
Prepare for the Transition Now
Whether you hold an Art. 1b licence or are planning your application: we assess your model against both the current and the coming regime — one partner from today’s licence to tomorrow’s.
