Swiss Federal Council launches consultation to update FINIA, strengthening fintech and crypto rules to boost innovation and global alignment.
Dr. Andreas Glarner
Legal Partner
Dominik Hofmann
Legal Partner
On October 22, 2025, the Swiss Federal Council opened the consultation on amendments to the Financial Institutions Act (FINIA). The goal is to strengthen the framework for innovative financial technologies, safeguard the attractiveness of Switzerland’s financial centre, and align with international standards – particularly regarding stablecoins and other cryptocurrencies.
What’s changing?
The proposal introduces two new licensing categories under FINIA, along with enhanced consumer protection measures:
1️. Payment Instrument Institution
Provides a license for stablecoin issuance
Expands the scope to allow comprehensive payment service provider activities under this licence
Replaces the previous Fintech licence
Removes the current CHF 100 million limit on public deposits
2️. Crypto Institution
A new licensing category for services related to crypto-based assets with trading characteristics, such as custody (including custodial wallet and staking services), brokerage services for clients, short-term proprietary trading, and crypto exchange activities
Adjusts settlement account regulations to enable broader crypto exchange services by Swiss providers
3️. Enhanced Consumer Protection
Select provisions of the Financial Services Act (FinSA) will now apply to crypto asset service providers (e.g. suitability and appropriateness tests, disclosure obligations, and conflict of interest management)
Whitepaper requirement for public offerings of crypto assets with trading characteristics, issuance of stablecoins, or requests for admission of crypto assets with trading characteristics to a DLT trading system
Our Take
We welcome the Federal Council’s initiative to strengthen the framework for innovative financial technologies and will carefully review the proposed amendments during the consultation process. Our experts are available for further questions or discussions at any time.
Next Steps
The consultation period now lasts until February 6, 2026. Considering the feedback received during the consultation period, a revised draft will be prepared for discussion and finalization by the Swiss legislator. We anticipate that the proposed regulations will not be ready to take effect before 2027.
