FINMA FinTech Application: Documentation and Approval Process
A FinTech authorisation under Article 1b of the Swiss Banking Act is decided on the strength of its documentation. FINMA does not assess an idea — it assesses whether the organisation, governance and controls you describe are complete, consistent and workable.
This page sets out what FINMA expects in a submission, how the process runs, and where applications typically lose time.
What FINMA requires in a FinTech application
The submission is a single, internally consistent package. Each document is read against the others, and contradictions between them are the most common reason a review stalls.
- Business plan and description of the intended activities
- Financial plan, capital evidence and proof of minimum capital
- Organisational regulations, governance structure and organigram
- Fit-and-proper documentation for the responsible persons
- AML and KYC framework, including client onboarding and monitoring
- Risk management concept and internal control system
- IT, security and outsourcing concept, including third-party arrangements
The exact scope depends on the business model. We assess which documents are required in your case before drafting begins.
The application process, step by step
Feasibility
We establish whether Article 1b is the right basis for your model, or whether a different authorisation applies, and identify the points FINMA will scrutinise.
Documentation
We draft and assemble the full submission package, coordinating business, financial, legal and IT content into one consistent set.
Submission
The application is filed with FINMA, together with the supporting evidence and the responsible persons’ documentation.
Review and questions
FINMA reviews and comes back with questions. How quickly and completely these are answered largely determines the overall duration.
Authorisation
FINMA grants the authorisation, subject to any conditions. Operational readiness has to be in place before business commences.
What a FINMA FinTech application costs
There is no fixed fee for a FinTech authorisation. Under the FINMA Fees and Charges Ordinance, procedures without a set rate are charged according to the time spent and the significance of the matter, with hourly rates depending on the seniority of the FINMA staff involved.
The practical consequence matters more than the rate itself: the cost of your application is driven by how much review time it consumes. A complete, internally consistent submission is reviewed once. An incomplete one generates rounds of questions — and each round is billable time as well as calendar time.
- FINMA fees — time-based, no published flat rate
- Audit firm confirmation on the application — a separate, mandatory cost
- Advisory and drafting work — depends on how much documentation already exists
Once supervised, institutions are also subject to an annual supervisory levy. We set out the expected range for your specific case in the feasibility phase.
Where applications lose time
Most delays are not caused by the regulator. They are caused by submissions that raise more questions than they answer.
- A business plan and a financial plan that do not reconcile with each other
- Fit-and-proper documentation for the responsible persons submitted late or incomplete
- Outsourcing described in the concept, but without the corresponding contracts and controls
- Generic concepts that do not visibly reflect the actual business model
- Applying under Article 1b when the model in fact requires a banking licence
Getting the scope right first
Not every model belongs under Article 1b. The deposit threshold, the treatment of client funds and the intended services determine whether a FinTech authorisation is sufficient or a banking licence is required. Choosing the wrong basis is expensive to correct later — we cover this on our Swiss FinTech licence page.