Business Licenses in Switzerland: SRO, Fintech and More

Which Businesses Need a License in Switzerland?

Switzerland follows a liberal approach to business regulation. Most commercial activities can be carried out without a specific government license once a company is registered in the commercial register. However, certain sectors are subject to mandatory licensing or permit requirements, either at the federal or cantonal level.

Activities that typically require licensing or regulatory approval include:

• Financial services: Banking, securities dealing, insurance, asset management, payment services, and money transmission
• Anti-money laundering (AML) regulated activities: Any financial intermediary activity, including crypto exchanges and trust companies
• Healthcare: Hospitals, pharmacies, medical practices, and certain health-related services
• Hospitality: Restaurants, bars, and hotels (cantonal gastronomy licenses)
• Construction: Certain construction activities, particularly in cantons with specific trade requirements
• Security: Private security firms and detective agencies
• Transport: Public transport operators, taxi companies, and freight carriers
• Export controls: Companies dealing with dual-use goods, arms, or sanctioned items

The first step is to determine which regime applies to your business. Our licenses and permits service includes a regulatory mapping that identifies all applicable requirements for your specific activity.

SRO Membership: For Financial Intermediaries

The Swiss Anti-Money Laundering Act (AMLA / GwG) requires all financial intermediaries that are not directly supervised by FINMA to be affiliated with a recognised Self-Regulatory Organisation (SRO). This is not optional. Operating as a financial intermediary without SRO membership or direct FINMA supervision is a criminal offence.

Who Needs SRO Membership?

SRO membership is mandatory for a wide range of businesses that handle financial transactions or assets on behalf of clients:

• Payment service providers: Companies that transfer money or process payments on behalf of third parties
• Currency exchange operators: Both physical bureaux de change and online platforms
• Crypto exchanges and custodians: Platforms that exchange, transfer, or store virtual assets for clients fall under AMLA and require SRO affiliation
• Money transmitters: Businesses that send or receive money on behalf of clients, including hawala-style operators
• Trust companies: Entities that manage trusts, foundations, or similar structures for clients
• Corporate service providers: Companies that provide domiciliation, nominee director, or formation services for third-party entities
• Loan brokers and crowdfunding platforms: Intermediaries connecting borrowers with lenders
• Insurance brokers: Those acting as intermediaries for insurance products (though some fall under FINMA directly)

Which SROs Exist?

FINMA has recognised several SROs, each with its own membership requirements, fees, and focus areas. The main ones include:

SRO Application Process and Timeline

Joining an SRO involves a structured application process:

1. Preparation (2-4 weeks): Draft internal AML policies, compliance manuals, and risk assessment frameworks. Appoint a qualified AML compliance officer. Prepare the business description, organisational chart, and beneficial ownership documentation.
2. Application submission: Submit the full application package to your chosen SRO, including all required documents, compliance frameworks, and fee payment.
3. Review and due diligence (4-8 weeks): The SRO reviews your application, may request additional documentation, and conducts background checks on beneficial owners and key personnel.
4. Decision: The SRO issues its decision. If approved, membership becomes effective and you can commence regulated activities. If rejected, you typically have the opportunity to address shortcomings and reapply.

Total timeline: Expect 2-4 months from start to SRO membership, depending on the complexity of your business and the completeness of your application.

Costs: SRO application fees range from CHF 2,000 to CHF 10,000, with annual membership fees of CHF 1,500 to CHF 5,000 depending on the SRO and the size of your business. Additional costs for external compliance consultants or AML manual preparation should be budgeted separately. Having the right corporate structure in place before applying streamlines the process.

Fintech License (FINMA)

Switzerland introduced the fintech license in 2019 as a bridge between the unregulated space and a full banking license. It was specifically designed to support innovation in financial technology while maintaining appropriate oversight.

What the Fintech License Allows

A fintech license permits a company to:

• Accept public deposits of up to CHF 100 million
• The deposits may not be invested or bear interest (they must be held, not lent out)
• Operate payment, settlement, and clearing systems
• Provide custodial services for digital assets

The fintech license is particularly relevant for:

• Digital payment platforms and e-money issuers
• Cryptocurrency custodians handling client deposits
• Crowdlending and crowdfunding platforms that hold client funds
• Blockchain-based settlement platforms

Requirements and Capital

Key requirements for a fintech license include:

• Minimum capital: CHF 300,000 (must be fully paid in)
• Organisation: Adequate risk management, internal controls, and governance structures
• Fit and proper: Directors and qualified participants must meet good reputation and professional competence standards
• Audit: Appointment of a recognised audit firm for annual regulatory audits
• AML compliance: Full compliance with the Anti-Money Laundering Act, either through direct FINMA supervision or SRO membership
• Swiss nexus: Effective management must be in Switzerland

How It Differs from a Full Banking License

The fintech license is deliberately lighter than a full banking license:

The fintech license is an excellent stepping stone for companies that need to accept and hold client funds but do not want the cost and complexity of a full banking license. Many fintech startups begin with an SRO membership, graduate to a fintech license as volumes grow, and eventually apply for a banking license if they want to offer lending and interest-bearing accounts.

SECO Permits: Export Controls and Dual-Use Goods

The State Secretariat for Economic Affairs (SECO) administers Switzerland's export control regime. Companies that manufacture, trade, broker, or transit certain categories of goods need SECO authorisation:

• Dual-use goods: Items with both civilian and military applications, such as certain electronics, chemicals, software, and precision instruments. The control list is based on international agreements (Wassenaar Arrangement, Nuclear Suppliers Group, Australia Group, MTCR).
• Military goods: Arms, ammunition, and military equipment require a specific war material permit under the War Material Act (KMG).
• Sanctioned goods: Goods subject to international sanctions (UN, EU-aligned Swiss sanctions) require SECO clearance.
• Nuclear materials: Special authorisations required under nuclear energy legislation.

If your Swiss company trades internationally in technology, chemicals, or precision instruments, verifying whether your products fall under export control lists is an essential compliance step. Violations carry severe penalties, including criminal prosecution. A ready-made shelf company can be set up quickly, but the export license application itself requires careful preparation.

Cantonal Permits and Licences

Many day-to-day business licences are administered at the cantonal level. Requirements vary by canton, so the location of your business matters. The most common cantonal licences include:

• Gastronomy licence (Gastwirtschaftspatent): Required for restaurants, bars, cafes, and hotels. The applicant (typically the designated manager) must pass a cantonal examination and demonstrate professional qualifications. Requirements and fees vary by canton.
• Healthcare licences: Medical practices, dental offices, pharmacies, and other healthcare providers need cantonal authorisation. This usually requires proof of professional qualifications (Swiss or recognised foreign diploma) and registration with the relevant cantonal health authority.
• Construction permits: Beyond building permits (Baubewilligung), some cantons require trade-specific licences for electrical installations, plumbing, and similar activities. The designated technical supervisor must hold recognised qualifications.
• Security services: Private security companies need cantonal permits, and employees may need individual authorisations. Criminal background checks and professional training requirements apply.
• Real estate brokerage: Some cantons require real estate agents and brokers to hold a cantonal licence or registration.

For foreign entrepreneurs, navigating cantonal requirements can be particularly challenging because they often differ significantly from one canton to another. What is freely permitted in Zurich may require a licence in Geneva, and vice versa. Our team handles the cantonal permit research and application as part of our licensing service.

Timeline and Cost Expectations

Licensing timelines in Switzerland vary widely depending on the type of licence and the completeness of your application:

These figures represent direct regulatory costs. Professional advisory fees for preparing applications, drafting compliance manuals, and managing the process are additional. Engaging experienced advisors typically accelerates timelines and reduces the risk of rejection. If you are starting a business as a foreigner in Switzerland, licensing requirements should be factored into your planning timeline from the outset.

Frequently Asked Questions