--- title: "Switzerland Crypto Regulation Monitor | cryptoassets.gi" canonical: https://cryptoassets.gi/jurisdictions/switzerland/ source_html: /jurisdictions/switzerland/index.html description: "Switzerland crypto asset regulation: 9 categories, 55 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment." generated_at: 2026-11-07T14:19:44Z content_sha256: 893d386fb2df0bc605804bb9c882f33c745e8c02d38fd9766c3ff8130547677d generator: "fe-fleet/md-twin@1.0" --- # Switzerland Crypto & Digital Asset Regulation schema crypto-v2.0.0 trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/switzerland/), [World Payments](https://payments.gi/jurisdictions/switzerland/) Last updated 2026-11-04 · 9 categories · 55 sourced findings · 79 sources in the cumulative register Download report (PDF) Expand all Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently. Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26 [Open in Co-Pilot ↗](/reports/?type=copilot&j=SWITZERLAND)[Build Report](/reports/?j=SWITZERLAND)[Compare](/compare/?j=SWITZERLAND) Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified Lead supervisory authority FINMA Primary statutory & supervisory perimeter Next milestone (> 2026-10-26) 2027-01-01 CARF automatic crypto-asset information exchange effective Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed 9 Categories 0 Moved this cycle 0 Key judgments 3 Open gaps 55 Findings 2 Tier-1 sources Confidence mix 9 unpopulated (sums to 9 rendered categories; click to filter) No categories moved this cycle. ## Jurisdiction lead brief ###### Latest update · 4 November 2026 #### Lead Signal The clearest movement in Switzerland's crypto oversight this period sits at the intersection of custody policy and product approval. Having set out, in January 2026, supervisory expectations for how banks, securities firms, managers of collective assets and portfolio managers must hold crypto-based assets - safekeeping, segregation per client, and comparable protection where custody sits with a foreign institution - the regulator then relied on that same standard nine months later when it cleared Switzerland's first retail-accessible Bitcoin exchange-traded fund. The approval, granted on 20 October 2026, included an exemption from the standard fund risk-diversification rules that would otherwise constrain a single-asset fund, with the custodian held to the January custody requirements. Read together, the sequence shows a regulator that wrote a technology-specific custody rulebook not as an abstract exercise but as groundwork for a specific category of retail product it expected to have to assess. #### Other Developments Days after the approval, the asset manager behind the product announced that it had received the authorisation for a Bitcoin fund exchange-traded fund trading under the ticker BBIT, describing it as the first Swiss-law exchange-traded fund investing directly in Bitcoin and open to retail investors. The announcement disclosed that the Bitcoin backing the fund is held with an international custodian. That detail, along with the retail-access characterisation, comes from the issuer's own announcement rather than from an independent statement by the supervisor identifying the custodian or confirming retail eligibility in those terms - a distinction worth holding onto when assessing how much weight the custodian relationship itself can bear. #### Cross-Monitor Connections No material connections to related financial-integrity, payments or cross-border monitoring work were identified in the sourcing reaching. #### Outlook The custody-guidance-into-product-approval sequence sets a template worth watching for future retail crypto products seeking Swiss market access: a supervisor-defined custody standard now doubles as the gating condition for exemptions from ordinary fund diversification rules. Whether other issuers pursue the same route, and whether the custodian arrangement disclosed by this issuer draws any further supervisory comment, are the natural points to track from here. 3 earlier updates not shown here. ###### Standing brief · as of 3 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal A Challenger-driven correction to Switzerland's consumer-protection posture is this cycle's most material development, though it corrects a stale record rather than reflecting new policy. A claim describing the Debt Enforcement and Bankruptcy Act's crypto-asset custody-segregation provisions (Articles 242a/242b) as merely "proposed" -- sourced originally to 2018-era secondary reporting -- has been corrected to reflect their actual status: enacted as part of the 2021 DLT Act package and in force since 1 August 2021. The correction is corroborated by the US Library of Congress's Global Legal Monitor and PwC Switzerland, with independent support from Chambers & Partners' 2025 Switzerland Blockchain practice guide. The underlying legal position was never in doubt among practitioners; what changed is the fidelity of this record, which had carried a five-year-stale "proposed" status until this cycle's fold. Practically, the correction upgrades certainty on a materially important protection: crypto-asset holders custodied through Swiss institutions have a statutory basis for having their assets segregated from an insolvent custodian's bankruptcy estate, rather than relying on an uncertain legislative proposal. #### Other Developments Switzerland's broader crypto posture remains what it has been for several years: a mature multi-track licensing perimeter built by fitting crypto activity into existing financial-services law rather than legislating a bespoke crypto statute. FINMA continues to operate parallel authorisation tracks -- a relaxed "fintech" license under the Banking Act for blockchain and cryptocurrency firms, a dedicated DLT Trading Facility license under the Financial Market Infrastructure Act for regulated tokenized-asset venues, a securities-house license track (evidenced by Crypto Broker AG's 2021 grant permitting it to hold client fiat funds and deal in regulated security tokens), and Banking Act custodian-bank licenses held by SEBA Bank and Sygnum. One sourcing gap surfaced this cycle: the evidence backing the DLT Trading Facility license claim for BX Digital in fact describes a related but distinct pan-European settlement platform (Boerse Stuttgart's Seturion), leaving BX Digital's own FINMA authorisation unconfirmed by direct primary source pending follow-up. Token classification remains anchored to FINMA's February 2018 ICO taxonomy, which continues to be cited internationally, including by ESMA's Securities and Markets Stakeholder Group. Under that taxonomy, payment tokens such as Bitcoin are treated as a means of payment rather than a security, utility tokens providing access to an application or service fall outside securities law, and asset tokens carrying an issuer claim trigger full securities-law obligations. Stablecoins are classified by reference asset and claim structure: currency- or commodity-backed coins with a contractual claim fall under banking law, security-backed coins fall under securities law, and basket-referenced coins with a redemption claim are treated as collective investment schemes. On the activity-regulation side, the 2021 DLT Act's creation of "ledger-based securities" gives legal effect to distributed-ledger-recorded ownership transfers without imposing a separate license requirement for tokenization itself -- a settled, in-force position. Other on-chain activity categories, including staking, DeFi lending, DEX operation, mining and validator activity, remain unevidenced against FINMA guidance this cycle and are treated as a known coverage gap rather than assumed to be unregulated. Switzerland's stablecoin landscape shows a settled classification route alongside an unfinished innovation track. Issuers can avoid a banking license by arranging a third-party bank "default guarantee" to repay depositors, and FINMA's July 2024 guidance tightened the associated safeguards, requiring that customers hold a direct claim against the guarantee-providing bank and that the guarantee fully cover deposits plus accrued interest. Separately, a consortium of major Swiss banks -- UBS, Sygnum, PostFinance, Raiffeisen, Zürcher Kantonalbank, Banque Cantonale Vaudoise and Swiss Stablecoin AG -- launched a live sandbox in 2026 to test a regulated Swiss-franc stablecoin. That sandbox is a voluntary industry pilot, not yet a binding reserve or redemption requirement, and Switzerland still lacks a broadly-used, regulated CHF stablecoin in force. Tax and cross-border coverage remain the thinnest parts of the Swiss picture this cycle. On tax, Switzerland is among a small number of jurisdictions to provide specific guidance on staking-reward income in addition to mining income, and the Canton of Zug continues to accept bitcoin and ether for cantonal tax payments, having raised its transaction threshold to CHF 1.5 million. A federal-level circular addressing capital-gains and wealth-tax treatment was not retrieved this cycle, so this remains a coverage gap rather than a finding of no such guidance. On cross-border transfer, FINMA requires Swiss virtual-asset service providers to verify the beneficial owner's identity for self-hosted-wallet transfers exceeding CHF 1,000 -- a threshold industry commentary described as stricter than the FATF baseline at time of adoption -- and this requirement was independently verified as accurate and current. #### Cross-Monitor Connections Two overlaps carry into adjacent monitors this cycle. The CHF 1,000 travel-rule identity-verification threshold sits at the AML/CFT boundary FINMA administers under its Anti-Money Laundering Ordinance; full analysis of that requirement belongs to the financial-integrity monitor's subscribed surface rather than to original crypto illicit-finance analysis here, and this record continues to track the AML/CFT module as an out-of-scope subscription pending consolidation. Separately, the cantonal tax-payment practice in Zug, the staking/mining income-tax characterisation, and the CHF-stablecoin consortium sandbox's default-guarantee redemption mechanics all carry payments-adjacent relevance that the world-payments monitor is better positioned to track in depth; this record retains licensing, issuance and classification analysis only. #### Outlook The clearest forward marker is the CHF-stablecoin bank consortium sandbox, expected to conclude around the fourth quarter of 2026. Its outcome will determine whether Switzerland moves from a voluntary pilot to a binding, broadly-used regulated Swiss-franc stablecoin regime, or whether the pilot structure persists without becoming a formal reserve/redemption requirement. Separately, this record's own coverage gaps -- primary FINMA/admin.ch confirmation of the ICO Guidelines, DLT Act statutory text and AMLO ordinance text, direct confirmation of BX Digital's DLT Trading Facility authorisation, the federal ESTV capital-gains circular, and on-chain activity categories beyond tokenization -- remain open items for future cycles rather than settled negatives. Read full brief · 1337 words Key regulatory facts for Switzerland Regulatory Dimension Switzerland Standing Position Jurisdiction Switzerland (CH) Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 55 sourced findings) Crypto Licensing Switzerland regulates crypto activity-based rather than token-based: most crypto businesses need only SRO membership under AMLA for AML purposes, while banking, securities, collective-investment or... Token Classification FINMA's February 2018 ICO taxonomy remains the operative test, distinguishing payment tokens (means of payment, not securities), utility tokens (access-only, not securities), and asset tokens (issuer claim, treated... On-Chain Activity Regime The 2021 DLT Act creates 'ledger-based securities', giving legal effect to ownership transfers of securities recorded on a distributed ledger, without a separate license requirement for tokenization itself, in force... Stablecoin Regime Stablecoin issuers can avoid a banking license via a third-party bank 'default guarantee', with FINMA's July 2024 guidance requiring a direct customer claim against the guarantee-providing bank and full coverage of... Primary Instruments Cited FINMA, FINMA, FINMA, FINMA, Federal Council FinIA amendment (payment instrument institution / crypto institution licences) Last Confirmed / Updated 2026-11-04 (79 sources in cumulative register) 9 of 9 categories Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### Switzerland: C1 Crypto LicensingGreenEnacted in forceModule confidence: Probable▾ Switzerland regulates crypto activity-based rather than token-based: most crypto businesses need only SRO membership under AMLA for AML purposes, while banking, securities, collective-investment or market-infrastructure functions trigger direct FINMA licensing under BankA, FinIA/FinMIA or CISA, plus the bespoke DLT trading-facility licence under the 2021 DLT Act. A FinIA-reform proposal (consultation closed 6 February 2026) would replace the fintech licence with Payment Instrument Institution and Crypto-Institution categories, but this remains at consultation/proposal stage with entry into force not expected before 2027. Open gap — crypto-int-1 Has the Federal Council filed its FinIA dispatch to Parliament since October 2026? no under-indexing note recorded Horizon · 2027 (± a year) FinIA reform: new payment-instrument and crypto-institution licences Consultation · Tier 3 source Horizon · 2027 (± a year) FinIA Payment Instrument Institution / Crypto-Institution licences Consultation · Tier 1 source Horizon · 2027 (± more than a year) FinIA reform: Payment Instrument Institution and Crypto-Institution licences Consultation · Tier 3 source Horizon · 2027 (± more than a year) Swiss FinIA Payment Instrument Institution / Crypto-Institution licences entry into force Consultation · Tier 3 source Horizon · 2027-Q1 (± a year) FinIA amendment creating payment instrument institution and crypto institution licences Consultation · Tier 1 source #### Crypto Licensing Switzerland's licensing regime for crypto and blockchain activity is defined by absence of a bespoke crypto-specific statute and presence of a well-developed set of parallel authorisation tracks fitted within existing financial-services law. FINMA, the federal supervisor, administers this multi-track perimeter across the Banking Act, the Financial Institutions Act, and the Financial Market Infrastructure Act, as amended by the 2021 DLT Act. The first track is a relaxed "fintech" license under the Banking Act, designed as a lighter-touch alternative to a full banking license specifically for blockchain and cryptocurrency-based firms. This license lowers the bar for firms that would otherwise need full banking authorisation purely because they accept public deposits in the course of their business, while still bringing them inside FINMA's regulatory perimeter rather than leaving them unregulated. A second track addresses market infrastructure directly: a dedicated DLT Trading Facility license under the Financial Market Infrastructure Act, which enables regulated venues to operate trading platforms for tokenized assets. BX Digital is cited as an example of a venue operating under this authorisation category. This claim carries a sourcing caveat worth flagging plainly: the retrievable evidence this cycle discusses a related pan-European tokenized-asset settlement platform (Boerse Stuttgart's Seturion) rather than directly evidencing BX Digital's own FINMA authorisation. The underlying license category itself is well-established, but the specific BX Digital attribution should be treated as provisional pending a FINMA-register or BX-Digital primary-source confirmation. A third track covers securities intermediation. FINMA granted Crypto Broker AG a securities-house license, enabling it to hold client fiat funds and deal in regulated security tokens -- a grant evidenced at the time it occurred via secondary reporting, and treated as a stable, unchanged feature of the perimeter since. The fourth track concerns custody. FINMA licensed dedicated crypto-custodian banks, including SEBA Bank and Sygnum, under the Banking Act, permitting them to act as custodian banks and to enable crypto-linked fund structures. These were the first FINMA-licensed institutions of this kind, and the category remains active with no indication of retrenchment. Across all four tracks, the pattern is consistent: Switzerland has chosen to regulate crypto activity by mapping it onto existing categories of licensed financial activity -- banking, securities dealing, custody, and market infrastructure -- rather than creating a single unified crypto license. This is a deliberate regulatory philosophy, not a gap, and it has now been tested and refined over several years of licensing grants across all four categories. #### Outlook No material change to this licensing perimeter is expected in the near term based on this cycle's evidence; the structure has been stable for several years and each track continues to see live authorisations. The most concrete open item is verification-level rather than structural: whether BX Digital's DLT Trading Facility authorisation can be confirmed against a FINMA register or primary BX Digital source, closing the sourcing gap identified this cycle. More broadly, this record's confidence in the licensing module rests on secondary reporting (T2/T4 tiers) rather than direct FINMA or admin.ch primary documents; a future cycle that retrieves FINMA's own licensing register or primary legal texts would allow this module's claims to move from Probable toward Confirmed confidence without any expected change in substance. Read full sub-brief · 528 words Periodic update · new data 2026-10-25 #### Crypto Licensing Switzerland's crypto licensing perimeter remains governed by its existing architecture, principally the DLT Act of 2021, FINMA's 2018 ICO and token guidelines, and the banking-law FinTech licence established under Article 1b of the Banking Act, while a significant reform to that architecture remains pre-enactment. A federal consultation that closed in February 2026 proposes replacing the current Article 1b FinTech licence with two new FINMA licence categories: a Payment Instrument Institution licence and a Crypto-Institution licence. This would be a structural change to how crypto-asset service providers and payment-instrument issuers are licensed in Switzerland, moving from a single generalist FinTech authorisation toward two more specialised categories. The confidence attached to the reform's substance is probable, resting on legal commentary describing the consultation's proposed structure. The confidence attached to its timing, however, is genuinely disputed: two sources retrieved diverge on whether the new categories take effect in 2027 or 2028, and neither traces to a FINMA primary consultation report or Federal Council decision retrieved. This is a material gap for any firm planning its licensing strategy under the current regime, since the transition mechanics from the existing FinTech licence to whichever new category applies, and the precise effective date, cannot yet be confirmed from primary sources. On enforcement, no Switzerland-specific crypto-service enforcement-penalty provision distinct from the general FINMA and Banking Act unauthorised-activity regime was located. This is a negative finding rather than evidence of an enforcement gap: it indicates that crypto-specific licensing violations in Switzerland continue to be addressed through the same general unauthorised-financial-activity framework that applies across FINMA's broader supervisory remit, rather than through a bespoke crypto enforcement provision. The proposed Crypto-Institution category, running alongside the Payment Instrument Institution category, suggests that the reform intends to differentiate licensing requirements for firms whose primary activity is crypto-asset-focused (such as exchange, custody, or trading services) from those whose primary activity is payment-instrument-focused (such as stablecoin issuance or payment processing). This differentiation, if it survives into the final rule, would represent a more granular approach to market-access licensing than the current single-category FinTech licence provides. #### Outlook The principal open item remains resolution of the disputed 2027-versus-2028 entry-into-force date, which a FINMA primary source would likely settle. Firms currently operating under, or considering application for, the existing Article 1b FinTech licence should treat the transition to either new category as a live planning consideration without yet being able to rely on a confirmed effective date, as scheduled. The interaction between the proposed Crypto-Institution and Payment Instrument Institution categories, and whether a single firm might need to hold both, is also not yet resolved from the material available. 2 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Crypto Licensing Switzerland's crypto-licensing framework currently rests on the Article 1b Banking Act fintech licence, alongside the Anti-Money Laundering Act, the Financial Institutions Act, the Financial Market Infrastructure Act, the Collective Investment Schemes Act, and the 2021 DLT Act, all supervised by FINMA. This settled, in-force structure faces near-term structural uncertainty from the FinIA-reform consultation, which closed on 6 February 2026 and proposes replacing the fintech licence with two new categories. The Payment Instrument Institution licence would remove the current CHF 100 million deposit cap, require mandatory client-fund segregation, and grant an exclusive right to issue Swiss-issued value-stable crypto-payment instruments accompanied by a published whitepaper. The Crypto-Institution licence would cover custody, trading, and staking activities distinctly from payment-instrument issuance. Expected entry into force of the reform is not before 2027, with some sources citing 2028, meaning operators entering the Swiss market in the near term will do so under the existing fintech-licence regime rather than the proposed categories. The bill text and its exact parliamentary timetable were not retrieved directly from admin.ch this cycle, so the precise legislative sequencing beyond "not before 2027" cannot be stated with greater precision. #### Outlook The consultation-to-bill transition is the marker to watch: until a bill is tabled with a parliamentary timetable, the 2027-or-2028 entry-into-force estimate remains the only available guidance. Operators planning for the new Payment Instrument Institution or Crypto-Institution categories should treat the current fintech-licence regime as the operative framework for any near-term market entry. Periodic update · new data 2026-09-28 #### Crypto Licensing Switzerland's crypto-licensing framework centres on FINMA's oversight, with the standard compliance path for exchanges, brokers, OTC desks, and payment processors being membership in a FINMA-recognised self-regulatory organisation (SRO) rather than direct licensing. The DLT Trading Facility licence under the DLT Act, first granted to BX Digital AG in March 2025 for regulated trading and settlement of DLT securities, remains the standing baseline for that specific activity and is unchanged this cycle. The material development this cycle is a Federal Council consultation, closed 6 February 2026, on amendments to the Financial Institutions Act (FinIA) proposing a new crypto-institution licence for custody and trading of crypto-assets with trading characteristics, which would move that activity from SRO oversight to direct FINMA prudential supervision. This is assessed as a structural tightening of the licensing regime, though the reform remains at consultation stage and is not expected in force before 2027 at the earliest. #### Outlook Watch for the Federal Council's formal response to the FinIA consultation and any published draft legislative text. If the crypto-institution licence proceeds broadly as proposed, firms currently operating custody or trading activity for crypto-assets with trading characteristics under SRO membership should expect a transition toward direct FINMA licensing and supervision, with the earliest plausible effective date being 2027. 1 further periodic run re-emitted the standing brief unchanged and is not shown. Sources and findings (10) - T3 · CoinDesk[FINMA](https://coindesk.com/swiss-government-to-regulate-blockchain-within-existing-financial-laws) — a relaxed 'fintech' license under the Banking Act as a lighter-touch alternative to a full banking license for blockchain and cryptocurrency-based firms - T3 · CoinDesk[FINMA](https://www.coindesk.com/business/2025/09/04/boerse-stuttgart-unveils-pan-european-settlement-platform-for-tokenized-assets) — a dedicated DLT Trading Facility license under the Financial Market Infrastructure Act, enabling regulated venues (e.g., BX Digital) to operate trading platforms for tokenized assets - T3 · CoinDesk[FINMA](https://www.coindesk.com/business/2021/02/01/switzerlands-crypto-broker-ag-wins-securities-house-license-from-finma) — a securities-house license to Crypto Broker AG, enabling it to hold client fiat funds and deal in regulated security tokens - T3 · CoinDesk[FINMA](https://www.coindesk.com/business/2021/09/29/switzerlands-seba-bank-snags-first-finma-license-for-liquid-crypto-funds) — dedicated crypto-custodian banks (e.g., SEBA Bank, Sygnum) under the Banking Act, permitting them to act as custodian banks and enable crypto-linked fund structures - T1[Federal Council FinIA amendment (payment instrument institution / crypto institution licences)](https://caplaw.ch/2026/the-new-payment-instrument-institutionslicense-under-the-revised-swiss-financial-institutions-act-an-opportunity-forforeign-payment-service-providers/) — Proposed 'payment instrument institution' licence (replacing 2018 FinTech licence, removing CHF 100m deposit cap) and 'crypto institution' licence; consultation closed 6 February 2026; no dispatch to Parliament as of October 2026. - T1 · Swiss Federal Administration[FinMIA payment-system and DLT trading facility licensing](https://www.newsd.admin.ch/newsd/message/attachments/42658.pdf) — FinMIA provides conditional payment-system authorisation and the DLT trading facility licence category - T1 · FINMA[DLT Act / FinMIA Art. 73a-73e](https://www.finma.ch/en/documentation/dossier/dossier-fintech/innovation-2021/) — DLT Act entered into force 1 August 2021, creating the DLT trading facility licence category - T1 · State Secretariat for International Finance (SIF)[FinIA reform draft 2025 (payment instrument institution / crypto-institution licences)](https://www.sif.admin.ch/fileservice/sdweb-docs-prod-sifadminch-files/files/2025/10/21/0bcd26d5-1fbd-4750-b459-de3ec0c36b76.pdf) — Federal Council opened consultation on 22 October 2025 (closed 6 February 2026) on new FINMA-supervised licence categories replacing the Art. 1b BankA FinTech licence; expected in force 2027 at earliest - T3[Swiss Federal Council (FinIA revision)](https://caplaw.ch/2026/the-new-payment-instrument-institutionslicense-under-the-revised-swiss-financial-institutions-act-an-opportunity-forforeign-payment-service-providers/) — A new Payment Instrument Institution licence category that will replace the current FinTech licence under Art. 1b of the Banking Act. - T1[Switzerland (crypto-service enforcement)](https://www.finma.ch/en/) — No CH-specific crypto-service enforcement-penalty provision distinct from the general FINMA/Banking Act unauthorised-activity regime was located this cycle. ### Switzerland: C2 Token ClassificationGreenEnacted in forceModule confidence: Probable▾ FINMA's February 2018 ICO taxonomy remains the operative test, distinguishing payment tokens (means of payment, not securities), utility tokens (access-only, not securities), and asset tokens (issuer claim, treated as securities). A related stablecoin classification-by-reference-asset framework applies banking law, securities law, or collective-investment-scheme treatment depending on backing and claim structure. No bespoke stablecoin statute exists. C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-11-04 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login) [View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Switzerland: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾ The 2021 DLT Act creates 'ledger-based securities', giving legal effect to ownership transfers of securities recorded on a distributed ledger, without a separate license requirement for tokenization itself, in force since 2021-08-01. Other on-chain activity categories (staking, DeFi, mining, node/validator operation) remain unevidenced this run -- a coverage gap, not a finding of no regulation. C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 3 traced claims · Re-verified 2026-11-04 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Switzerland: C4 Stablecoin RegimeAmberEnacted in forceModule confidence: Probable▾ Stablecoin issuers can avoid a banking license via a third-party bank 'default guarantee', with FINMA's July 2024 guidance requiring a direct customer claim against the guarantee-providing bank and full coverage of deposits plus accrued interest. A major bank consortium (UBS, Sygnum, PostFinance, Raiffeisen, ZKB, BCV, Swiss Stablecoin AG) launched a live sandbox in 2026 to test a regulated CHF stablecoin; Switzerland does not yet have a broadly-used regulated CHF stablecoin in force. Periodic update · new data 2026-10-25 #### Stablecoin Regime The proposed Payment Instrument Institution licence, discussed in the licensing context above, is directly tied to a significant proposed change in Switzerland's stablecoin regime: exclusive authority for licence-holders to issue a specific category of CHF stablecoin. The proposed design requires that the stablecoin be fully backed, that the backing assets be segregated from the issuer's own assets, that holders be entitled to redeem at par value, and that issuance be accompanied by a whitepaper meeting a defined disclosure duty. This would represent a materially more structured regime than currently exists, where stablecoin issuance in Switzerland is addressed through a combination of banking, securities, and token-taxonomy principles applied case by case rather than through a single dedicated licence category. This development remains pre-enactment, and its confidence is assessed as probable, reflecting that it derives from legal commentary on a proposed reform rather than an enacted instrument. The exclusivity feature is the most structurally significant element: if it survives into the final rule, only Payment Instrument Institution licence-holders would be permitted to issue this category of CHF stablecoin, creating a licensing gate around CHF-referenced token issuance that does not currently exist under Swiss law. The segregation and par-redemption requirements both address classic stablecoin risks directly. Requiring that backing assets sit outside the issuer's own balance sheet is intended to protect token holders from the issuer's own insolvency, while the par-redemption right is intended to anchor the token's secondary-market value to its backing. These features would sit alongside Switzerland's existing, long-standing payment/utility/asset token taxonomy, which continues to govern how fiat-referenced and other tokens are characterised outside the specific proposed stablecoin-issuance framework; that taxonomy has not changed and is not itself part of the pending reform. Because Switzerland is not an EU or EEA member, the EU's Markets in Crypto-Assets Regulation and its own electronic-money-token and asset-referenced-token categories do not apply in Switzerland. The proposed Payment Instrument Institution framework should therefore be understood as a distinct, autonomously designed Swiss approach to fiat-referenced token regulation, running on its own track and timeline rather than mirroring the EU's categories or implementation schedule. #### Outlook The stablecoin-specific elements of the reform are tied to the same disputed 2027-versus-2028 timeline affecting the broader licensing reform, and resolution of one is likely to resolve the other given their apparent integration as a single legislative package. Firms considering CHF stablecoin issuance in Switzerland should treat the segregation, par-redemption, and whitepaper requirements as the probable shape of the eventual regime, while recognising that the exclusivity scope and the treatment of any issuance occurring before the new licence takes effect remain unconfirmed pending a FINMA primary source. Periodic update · new data 2026-10-11 #### Stablecoin Regime Switzerland's current stablecoin regime operates under FINMA Guidance 06/2024, which permits a fiat-referenced stablecoin to be offered without a full banking licence where investor redemption claims are covered by an irrevocable Swiss bank guarantee and AML/KYC rules are applied. Outside that structure, stablecoin issuance may constitute deposit-taking or banking business requiring a licence, meaning the current regime functions as a guidance-based carve-out rather than a dedicated statutory stablecoin framework. The FinIA-reform proposal would change this materially: only licensed Payment Instrument Institutions could issue a "stable crypto-based payment instrument" pegged to a single fiat currency, fully backed and segregated from the issuer's own assets, redeemable at par, and accompanied by a mandatory whitepaper. This is not yet enacted and remains at consultation stage, having closed on 6 February 2026. In parallel, Project Helvetia, the SNB's wholesale CBDC pilot conducted with SIX Digital Exchange, has been extended to at least mid-2027 as the live settlement-asset track for tokenized securities settled in SNB money. The SNB's dispatch on a durable legal framework for this pilot was expected in the second half of 2026 at the earliest, with no known publication as of early October 2026, leaving both the private stablecoin-issuer framework and the sovereign wholesale-CBDC legal framework in a parallel transitional state. #### Outlook Two separate durable-framework questions remain open on parallel but distinct tracks: whether the FinIA reform progresses from consultation toward an enacted Payment Instrument Institution category restricting stablecoin issuance, and whether the SNB publishes its expected dispatch on a durable wholesale-CBDC legal framework. Neither had moved as of this cycle. Periodic update · new data 2026-09-28 #### Stablecoin Regime FINMA Guidance 01/2026 tightens the custody, segregation, private-key management, and bankruptcy-protection expectations for crypto-based assets, including foreign-custodian-equivalence requirements where custody is outsourced outside Switzerland; this is a binding instrument already in force. Separately, the FinIA consultation that closed 6 February 2026 proposes a payment-instrument institution licence that would explicitly permit issuance of value-stable crypto-based means of payment, i.e., stablecoins, and would remove the CHF 100 million client-funds cap currently applicable to the existing FinTech licence. Together, these developments point toward a Swiss stablecoin framework that combines tightening operational custody standards today with a more permissive institutional-licensing pathway for regulated stablecoin issuance in future, contingent on the FinIA reform's enactment. The custody guidance and the licensing reform should not be conflated: the guidance addresses how existing SRO-affiliated and licensed firms handle client crypto-assets today, under the current regime, while the FinIA proposal addresses a future question of who may provide those services at all, and under what prudential licence, once and if the reform is enacted. Firms currently operating on the SRO-membership model under the Anti-Money Laundering Act should treat Guidance 01/2026 as an immediately binding compliance requirement, and the FinIA proposal as a medium-term structural risk to monitor rather than a current obligation. #### Outlook The FinIA reform, if enacted substantially as proposed, would represent the first Swiss licence explicitly contemplating regulated stablecoin issuance at scale, unconstrained by the current CHF 100 million cap. Its progress from consultation toward a final text, expected no earlier than 2027, is the clearest signal to watch for firms planning Swiss stablecoin issuance. C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-11-04 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Switzerland: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾ DEBA custody-segregation provisions (Arts. 242a/242b, as amended by the 2021 DLT Act) were reclassified via Challenger fold from 'proposed' to confirmed enacted and in force since 2021-08-01, corroborated by the Library of Congress Global Legal Monitor, PwC Switzerland and Chambers & Partners. FINMA's ICO enquiry framework separately requires issuers to provide sufficient information on token function and rights as part of case-by-case assessment. Marketing restrictions, complaint-handling and suitability remain unevidenced this run. #### Consumer Protection This cycle's most consequential development across the entire Swiss record sits within consumer protection: a Challenger-driven correction to the status of the Debt Enforcement and Bankruptcy Act's crypto-asset custody-segregation provisions, Articles 242a and 242b, as amended by the 2021 DLT Act. The claim originally rested on a 2018-era CoinDesk article describing the segregation amendment as a Federal Council proposal -- carrying a "proposed" regulatory_stage, "Uncertain" confidence, and T4 source tier. This cycle's fold confirms that the provisions were in fact enacted as part of the 2021 DLT Act package and have been in force since 1 August 2021 -- a five-year gap between the provisions' actual entry into force and this record's prior "proposed" characterisation. The correction is now backed by the US Library of Congress's Global Legal Monitor and PwC Switzerland (both T2/T3 sources), with independent corroboration from Chambers & Partners' 2025 Switzerland Blockchain practice guide, and confidence has been upgraded from Uncertain to Probable accordingly. Substantively, these provisions give crypto-asset holders custodied through a Swiss institution a statutory basis for having their assets segregated from that custodian's bankruptcy estate in the event of its insolvency -- a foundational consumer-protection safeguard for anyone holding crypto assets through a regulated Swiss custodian rather than self-custodying. That the underlying legal position was correct in substance throughout the intervening years, and only this record's characterisation was stale, is itself worth noting: this was a data-fidelity correction, not a change in the law. Separately, FINMA's ICO enquiry framework requires issuers to provide sufficient information -- for example, on token function and rights -- as part of its case-by-case regulatory assessment of proposed token offerings. This operates as a disclosure mechanism embedded in the classification process itself (see token_classification) rather than as a codified, freestanding disclosure statute, and remains an active, unchanged feature of FINMA's practice. #### Outlook With the custody-segregation correction now applied, this module's confidence in its two evidenced categories -- custody segregation and disclosure via the ICO enquiry process -- is reasonably solid. However, several consumer-protection categories remain unconfirmed by direct sourced evidence this cycle: marketing restrictions, complaint-handling mechanisms, and suitability assessments for retail crypto products were not independently evidenced. A future cycle should prioritise direct research into these categories rather than assuming FINMA's broader consumer-protection posture mirrors the custody and disclosure findings already established here. Ideally, a future cycle would also confirm the DEBA correction against the current fedlex.admin.ch statutory text directly, rather than relying solely on secondary legal-monitor and law-firm reporting. Read full sub-brief · 413 words Periodic update · new data 2026-10-25 #### Consumer Protection FINMA's approval of Switzerland's first retail spot Bitcoin exchange-traded fund is a material, already-in-force development for consumer protection in the Swiss crypto space. FINMA stated that supervised institutions offering the product must take measures to mitigate the operational and custody risks associated with holding the underlying bitcoin, and must clearly explain those risks in the fund's documentation, with the Financial Services Act's conduct-of-business rules applying when the ETF is sold to retail investors. This is a confirmed development, resting on FINMA's own regulatory decision reported at the time of approval, and it represents a notable expansion of retail access to a bitcoin-backed product within a conduct-regulated fund-law wrapper, rather than through direct retail purchase of the underlying asset. The operational and custody risk-mitigation measures FINMA expects of supervised institutions, however, rest on a less specific statutory foundation than might be assumed. No Switzerland-specific crypto-custodian segregation statute analogous to the European Union's Markets in Crypto-Assets Regulation custody provisions was located. Instead, Swiss custody obligations in this context rest on general principles under the Financial Services Act and ordinary contract law, together with case-by-case FINMA guidance, rather than on a single dedicated statutory custody-segregation rule. This is a negative finding rather than an indication of a gap in actual practice, since the general FinSA and contract-law framework may in practice impose segregation-equivalent obligations on custodians; it reflects that no CH-specific statute dedicated to crypto-custody segregation, comparable to the more codified approach seen in some other jurisdictions, was identified. The conduct-of-business rules applying to the ETF's distribution under the Financial Services Act bring a layer of point-of-sale consumer protection that is more clearly defined than the underlying custody framework: these rules govern disclosure, suitability, and conduct obligations for the entities distributing the fund to retail clients, independent of the specific custody arrangements for the underlying bitcoin holdings. #### Outlook Further FINMA guidance on the specific operational and custody risk-mitigation measures expected of institutions offering bitcoin-backed retail products is a plausible next step, given the general rather than crypto-specific statutory foundation currently underpinning custody obligations. Whether Switzerland moves toward a more codified, crypto-specific custody-segregation rule, rather than continuing to rely on general FinSA and contract-law principles, remains an open question not resolved by the material available. 1 earlier distinct update(s) Periodic update · new data 2026-09-28 #### Consumer Protection FINMA's 2025 Annual Report explicitly warns of significant risks facing consumers in the crypto market and pushes for new licence categories for stablecoin issuers and crypto service providers as a partial remedy. This represents a hardening of supervisory tone rather than a new binding consumer-protection instrument: no new binding rule specific to consumer protection in crypto markets is evidenced in the record this cycle, but the annual-report language is consistent with, and appears to anticipate, the FinIA licensing proposals tracked elsewhere this cycle, which FINMA frames as part of the remedy for the consumer risks it has identified. #### Outlook Watch whether FINMA's hardened consumer-risk language in its 2025 Annual Report is followed by dedicated consumer-protection rulemaking specific to crypto markets, or whether the FinIA licensing reform is treated as sufficient remedy on its own. 1 further periodic run re-emitted the standing brief unchanged and is not shown. Sources and findings (11) - T2 · US Library of Congress, Global Legal Monitor[Switzerland (DEBA Articles 242a/242b, as amended by the 2021 DLT Act)](https://www.loc.gov/item/global-legal-monitor/2021-03-03/switzerland-new-amending-law-adapts-several-acts-to-developments-in-distributed-ledger-technology/) — a statutory basis allowing segregation of crypto-based assets from an insolvent custodian's bankruptcy estate - T2 · ESMA / Securities and Markets Stakeholder Group[FINMA](https://www.esma.europa.eu/sites/default/files/library/esma22-106-1338_smsg_advice_-_report_on_icos_and_crypto-assets.pdf) — issuers to provide sufficient information (e.g., on token function and rights) as part of its case-by-case regulatory assessment of token offerings under the ICO enquiry framework - T1[FINMA](https://crypto.news/switzerland-delays-automatic-crypto-tax-data-sharing-with-foreign-authorities-until-at-least-2027/) — Approved Switzerland's first retail-accessible Bitcoin ETF on 20 October 2026, granting exemption from standard fund risk-diversification rules, requiring the fund's custodian to apply FINMA's January 2026 custody standards. - T3[FINMA Guidance 01/2026 on the custody of crypto-based assets](https://www.finma.ch/en/) — Sets supervisory requirements for custody of crypto-based assets by Swiss-regulated institutions (banks, securities firms, managers of collective assets, portfolio managers), following the DLT Act's enhanced insolvency protection. - T3 · PwC Switzerland[FINMA Guidance 01/2026 on custody of crypto-based assets](https://www.pwc.ch/en/insights/fs/new-finma-guidance-on-crypto-custody-requirements.html) — crypto-based assets held by banks and individual portfolio managers - T3 · ISP Group[FINMA Guidance 01/2026 on custody of crypto-based assets](https://ispgroup.com/insights/what-finmas-new-crypto-custody-guidance-means-for-asset-managers-and-their-clients) — foreign sub-custodians of client crypto assets - T1 · FINMA[FINMA supervisory assessment on staking](https://www.finma.ch/en/news/2023/12/20231220-meldung-am-staking/) — insolvency of custodial staking service provider - T1 · FINMA[FinMIA Arts. 142-143](https://www.finma.ch/en/enforcement/market-supervision/market-abuse/) — financial instruments (e.g. asset tokens treated as securities) - T3 · ZUG DLT[FinSA Art. 35 ff.](https://zugdlt.com/legislation/swiss-finsa-dlt/) — public offering of asset tokens treated as securities to retail investors - T3[FINMA (retail spot Bitcoin ETF approval)](https://www.theblock.co/news/regulation/2026-10-20-swiss-regulator-finma-approves-countrys-first-spot-bitcoin-etf-for-retail-investors-421127) — FINMA said supervised institutions must take measures to mitigate operational and custody risks and clearly explain them in fund documents, with FinSA rules of conduct applying when the ETF is sold. - T1[Switzerland (crypto custody segregation)](https://www.finma.ch/en/) — No CH-specific crypto custodian-segregation statutory rule analogous to MiCA Art 75 was located this cycle; Swiss custody obligations rest on general FinSA/contract-law principles and FINMA guidance. ### Switzerland: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾ Switzerland provides specific tax guidance on staking-reward income in addition to mining income, one of a small number of jurisdictions to do so. The Canton of Zug (cantonal level) permits settling cantonal tax liabilities directly in bitcoin and ether, with the transaction threshold raised to CHF 1.5 million. Federal-level capital-gains/wealth-tax circular coverage was not retrieved this run. Horizon · 2027-01-01 (± a quarter) CARF automatic crypto-asset information exchange effective Adopted, not yet in force · Tier 3 source Periodic update · new data 2026-10-11 #### Tax Treatment Automatic exchange of crypto-asset information under the OECD's Crypto-Asset Reporting Framework has been delayed in Switzerland from the originally planned January 2026 start to at least January 2027. The underlying legislative basis will still be enacted during 2026, but the CARF-specific provisions under the Swiss Automatic Exchange of Information ordinance will not apply during 2026 itself, creating a one-year transitional reporting gap relative to the original implementation timetable. This delay sits within the broader Swiss tax-treatment framework for crypto assets, which is otherwise governed by existing Federal Tax Administration and Federal Council instruments. The CARF delay does not alter the substantive tax treatment of crypto-asset holdings or transactions themselves; it affects only the timing of automatic cross-border information exchange about those holdings. #### Outlook The fixed marker to watch is 1 January 2027, when CARF-specific automatic exchange provisions are expected to become operative under the AEOI ordinance. Until that date, the legislative basis enacted during 2026 will exist without the CARF-specific exchange mechanism yet applying, a transitional state that firms with Swiss crypto-asset exposure should track against their own cross-border reporting obligations. C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Switzerland: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾ FINMA requires Swiss VASPs to verify the identity of the beneficial owner of a self-hosted wallet before allowing crypto transfers exceeding CHF 1,000, a threshold industry commentary described as stricter than the FATF baseline at adoption; verified as accurate and current by the Challenger. Broader outbound-restriction/sanctions-nexus categories were not sourced this run. Horizon · 2027 (± a year) Swiss cross-border automatic CARF crypto tax data exchange begins Adopted · Tier 3 source Periodic update · new data 2026-10-25 #### Cross-Border Transfer Switzerland's cross-border crypto tax-transparency framework moved on two distinct timelines, and distinguishing between them matters. The Crypto-Asset Reporting Framework was incorporated into Swiss domestic legislation with effect from 1 January 2026; this is a confirmed, already-in-force legal development establishing the domestic statutory basis for crypto-asset tax reporting. However, the practical cross-border exchange of crypto account information with foreign tax authorities under that framework is a separate matter, governed by a distinct operative date that has been delayed to at least 2027. The delay in practical cross-border exchange traces to a specific procedural development: the National Council's Economic Affairs and Taxation Committee placed its review of the proposed partner-jurisdiction list on hold in November 2025, pushing back the effective start of actual data exchange with foreign authorities. This is assessed as probable rather than confirmed, since it reflects a procedural, pre-enactment legislative development rather than a finalised statutory instrument, and the regulatory stage for this element is proposed rather than in force. The distinction between these two dates, the confirmed domestic legal effective date of 1 January 2026 and the probable cross-border operative date of 2027 at the earliest, is analytically important. A domestic reporting obligation can be in force as a matter of Swiss law while the cross-border information-sharing mechanism that gives that obligation its international effect remains suspended pending parliamentary review of which countries will participate as exchange partners. Firms and individuals subject to Swiss crypto-asset reporting obligations should not conflate the domestic legal effective date with the later date at which foreign tax authorities will actually begin receiving Swiss-sourced crypto account data. This cross-border delay sits alongside, but is analytically distinct from, the pending Payment Instrument Institution and Crypto-Institution licensing reform discussed elsewhere; the two developments proceed on independent legislative and administrative tracks even though both bear on Switzerland's broader crypto-asset regulatory posture. #### Outlook The partner-jurisdiction list review by the National Council's Economic Affairs and Taxation Committee is the key procedural item to watch for any firm or individual needing to anticipate when actual cross-border crypto tax data exchange will begin. Until that review concludes, 2027 should be treated as the earliest plausible start date for practical exchange, as scheduled, while the domestic reporting obligation under Swiss law continues to apply from its confirmed 1 January 2026 effective date regardless of the cross-border timeline. Periodic update · new data 2026-10-11 #### Cross-Border Transfer The Swiss Federal Council has approved automatic crypto-asset data exchange with 74 partner jurisdictions, covering all EU member states, the United Kingdom, and most G20 countries. The United States, China, and Saudi Arabia are explicitly excluded from this exchange arrangement. Participation is conditioned on partner jurisdictions meeting OECD CARF standards and offering reciprocal exchange, and the arrangement is scheduled to become effective from 1 January 2027, consistent with the broader CARF implementation delay recorded under tax treatment. This cross-border exchange architecture is a direct extension of Switzerland's adoption of the OECD Crypto-Asset Reporting Framework, and the exclusion of three major jurisdictions, including the world's largest crypto-asset market by some measures, is a notable scoping decision that confines the exchange network to CARF-compliant, reciprocal partners only. #### Outlook The exchange network's effective date of 1 January 2027 is the fixed marker to watch, aligned with the CARF-specific provisions becoming operative under the AEOI ordinance on the same date. Whether the excluded jurisdictions, particularly the United States, move toward CARF-standard reciprocity in the interim would be the development most likely to expand the network's coverage beyond the 74 currently approved partners. C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Switzerland: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾ AML/CFT for Switzerland is out of scope for this baseline by design: this module is subscribed from the financial-integrity monitor pending consolidation lock, and this record does not carry independent AML/CFT claims this cycle. C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Switzerland: C9 Commercial Activity ▾ No standing position recorded for this category. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. No periodic updates recorded in this cycle Sources and findings (3) - T3[FalconX](https://tracxn.com/d/explore/fintech-startups-in-zurich-switzerland/__mw9LHr8ONFucMp8OuMYMnHwMReyyxHGzIKrPP8gQrbw) — FalconX acquired 21Shares (Zurich-headquartered crypto ETP issuer) in a business acquisition dated 20 November 2025; deal value not disclosed in sources reviewed. (2× uses collapsed) - T2[BIT Asset Management AG](https://www.onvista.de/news/2026/10-22-eqs-news-bit-asset-management-erhaelt-finma-zulassung-fuer-den-ersten-schweizer-und-einzigen-europaeischen-spot-bitcoin-etf-0-37-26567284) — Announced 22 October 2026 that FINMA granted authorisation for its Bitcoin Fund ETF (ticker BBIT), the first Swiss-law exchange-traded fund investing directly in Bitcoin open to retail investors, with Bitcoin held in custody by Coinbase Custody International Limited.