FINIG — Swiss Financial Institutions Act

The Financial Institutions Act (FINIG) entered into force on 1 January 2020 and creates a graduated, uniform licensing framework for financial institutions in Switzerland. It replaces and harmonizes licensing requirements previously scattered across various laws (KAG, BankG).

• Graduated licensing: Five categories — asset managers, trustees, managers of collective investment schemes, fund management companies, securities firms
• New licensing obligation: For the first time, licensing requirement for independent asset managers and trustees
• Prudential supervision: Direct FINMA supervision or supervisory organization (AO)
• Organizational requirements: Minimum capital, risk management, internal controls
• Transitional periods: Existing asset managers had until end of 2022 to apply for licensing

Before FINIG, independent asset managers were only subject to GwG requirements (SRO) but had no prudential supervision. The FATF evaluation of 2016 sharply criticized this gap. In parallel, the equivalence debate with the EU (MiFID II) necessitated also regulating the institutional side.

FINIG was adopted together with FIDLEG by Parliament on 15 June 2018. The transitional period for existing asset managers to submit a licensing application ran until end of 2022; effective license grants continued well into 2023. FINIG established for the first time a two-tier model: supervisory organizations (AOs) take on ongoing supervision of smaller asset managers, with FINMA retaining meta-supervision.

On 1 August 2021, the amendment to FINIG under the DLT Act (Distributed Ledger Technology) entered into force. This revision introduced a new licence type — the DLT trading system — into financial market law, with points of contact to FINIG licensing categories.

On 22 October 2025, the Federal Council opened the consultation on revision of FINIG. The proposal envisages two new licensing categories: payment token institutions (for stablecoin issuers) and crypto institutions (for further crypto service providers). This aims to align Switzerland with developments in digital assets and close regulatory gaps.

FINIG applies to all financial institutions operating in Switzerland (graduated licensing categories):

• Securities firms: Trading in securities on own or third-party account
• Fund management companies: Managing Swiss collective investment schemes
• Managers of collective investment schemes: Managing funds (Swiss or foreign)
• Trustees: Administering trusts (typically governed by foreign law) operating from Switzerland
• Asset managers: Individual portfolio management for third parties

• Licensing requirement: Obtain license from FINMA before commencing activity
• Minimum capital: Depending on category (e.g., CHF 100,000 for asset managers)
• Qualification requirements: Senior managers with sufficient education and experience
• Organizational obligations: Risk management, internal controls, compliance function
• Affiliation with supervisory organization (AO): Smaller asset managers are subject to a licensed AO
• Reporting obligations: Material changes must be reported to FINMA
• GwG compliance: Fulfillment of all anti-money laundering provisions

"FinIA — Financial Institutions Act" was classified under theme "Jurisdiktion". Correct is "Finanzmarkt". National laws and authorities are classified by subject matter, not as Jurisdiction. Country profiles are classified as Jurisdiction.

3 corrections:
- Date of first AO recognition is wrong (1 September 2020 instead of 7 July 2020)
- last_amended date is outdated (2022-12-31 instead of 2024-03-01)
- official_url points to FINIV instead of FINIG
2 updates:
- Missing mention of DLT legislative adaptation (in force 1 August 2021)
- Missing mention of FINIG revision 2025 (stablecoins/crypto consultation)
1 clarification.