SFA Position on the Future of the Swiss FinTech Licence

The future of the Swiss FinTech licence is an important issue for the competitiveness of the Swiss financial centre. In its position paper, the Swiss Fintech Alliance (SFA) sets out the views of licensed FinTech companies, active applicants, and firms that have suspended their FINMA application process.

The SFA argues that Switzerland should preserve the original concept of the FinTech licence as a “Banking Light” regime under the Banking Act. This framework gives FinTech companies legal certainty, access to banking know-how and infrastructure, and a clear pathway towards a full banking licence.

Preserving Banking Light

A key concern is that the Swiss framework should not be converted into an electronic money institution or payment service provider model. In the SFA’s view, such a “Swiss EMI” approach would weaken Switzerland’s competitive position, especially because Switzerland does not benefit from EU passporting.

Instead, the SFA supports maintaining a regulatory model that is clearly anchored in Swiss banking law. This gives the Swiss FinTech licence a distinct profile compared with regimes in the EU and the UK.

CHF 100 Million Threshold

The SFA also highlights the practical challenges caused by the CHF 100 million public deposit threshold. This limit creates uncertainty for growing FinTech companies, affects investor confidence, and may force firms to slow down or turn away deposits as they approach the threshold.

The SFA therefore recommends removing or increasing the threshold. Alternatively, the transition process towards a full banking licence should be triggered earlier, for example when a company reaches 75 percent of the limit.

Ability to Pass Interest to Clients

Another important point concerns the ability to pass interest to clients. The SFA argues that FinTech companies should be allowed to transfer interest earned on deposits held with institutions such as the Swiss National Bank, the Swiss Euro Clearing Bank, or in high-quality liquid assets.

According to the SFA, this should be distinguished from traditional interest margin business, which would remain reserved for banks. Any related risks could be addressed through clear limits and safeguards.

Recommendation: Category 6 Banks

As a central recommendation, the SFA proposes that FinTech companies should be reclassified as Category 6 banks. This would keep them under banking law, improve international understanding, and allow the use of a clearer regulatory label.

At the same time, the current restrictions would remain in place. These include the prohibition of interest margin business, maturity transformation, and certain investment banking activities.

The SFA also notes that such a classification would help maintain access to important Swiss financial market infrastructure, including SNB sight deposit accounts, SIC, EuroSIC, and SECB.

Advantages for Switzerland

The proposed approach would support innovation in Switzerland, create a more coherent regulatory system, and avoid unnecessary new rules. It would also reduce confusion among foreign regulators, correspondent banks, payment service providers, and other market participants.

If the Category 6 bank proposal is not adopted, the SFA recommends at least maintaining the current Article 1b Banking Act framework and removing the CHF 100 million threshold.

Conclusion

Overall, the SFA position supports a clear, proportionate, and internationally understandable Swiss “Banking Light” regime. This would strengthen Switzerland’s attractiveness as a hub for FinTech innovation and digital financial services.

Download the full position paper:
SFA Position Paper on the Future of the Swiss FinTech Licence