The SIF consultation on fintech and stablecoins is an important step for the future of the Swiss financial centre. It addresses proposed amendments to the Federal Act on Financial Institutions, including new rules for payment institutions and crypto-asset service providers.
In response, the Swiss Fintech Alliance (SFA) has submitted a detailed position paper. The document reflects the practical experience of licensed FinTechs, active applicants, and market participants in Switzerland.
Industry-driven input
The SFA position is based on continuous dialogue with the Swiss fintech and crypto ecosystem. The FinTech Coalition K2 also supported the work with coordinated industry input.
Together, these organisations represent a broad part of the Swiss fintech and blockchain sector. As a result, the position paper addresses real operational challenges and practical market needs.
Key regulatory concerns
First, the SFA highlights the need for faster and more predictable licensing procedures. Long approval timelines increase costs and reduce Switzerland’s international appeal.
Second, the SFA calls for proportionate regulation. Capital requirements, liquidity rules, and group supervision should reflect the actual risk profile of fintech business models.
The SFA also stresses that Switzerland must remain competitive compared with the EU, the UK, and other global fintech hubs. Since Switzerland does not benefit from EU passporting, its regulatory framework must offer clear advantages.
Payment institutions and stablecoins
A central part of the SIF consultation on fintech and stablecoins concerns the proposed payment institution licence. The SFA welcomes the abolition of the CHF 100 million threshold, but recommends further improvements.
In particular, the SFA proposes that the licence should remain under the Banking Act and be positioned more clearly, for example, as a “Non-Credit Bank” or “Swiss FinTech Bank”.
The SFA also supports clear and practical rules for stablecoins. It welcomes the possibility for payment institutions to issue stablecoins, while calling for the removal of excessive secondary-market identification requirements.
Crypto-asset services
The SFA recommends a clear distinction between payment-related crypto services and higher-risk custody or investment services. Basic crypto payment and conversion services should remain possible under the existing SRO framework.
Higher-risk activities may require a FINMA licence. However, supervision should remain proportionate, efficient, and aligned with the real risks of the business model.
Legislative recommendations
The position paper includes an article-by-article review of the draft legislation. Key recommendations include statutory deadlines for FINMA licensing decisions, proportionate group supervision, risk-based capital requirements, clearer stablecoin rules, and transitional provisions for pending applications.
Conclusion
With its response to the SIF consultation on fintech and stablecoins, the SFA supports a strong, innovative, and future-ready Swiss financial centre.
The position paper welcomes important elements of the reform. At the same time, it calls for targeted improvements to preserve Switzerland’s competitiveness as a fintech, stablecoin, and crypto hub.
Download the full position paper:
SFA Position on the SIF Consultation on Fintech and Stablecoins
Related links:
State Secretariat for International Finance
Swiss Fintech Alliance
FINMA
