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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.
On the innovation side, a consortium of major Swiss banks and institutions -- 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. This is a voluntary industry pilot, not a binding reserve-and-redemption regulatory requirement, and its regulatory_stage is deliberately left unset in this record because it spans a forward, non-normative pilot phase rather than an enacted rule. Switzerland does not yet have a broadly-used, regulated CHF stablecoin in force; the sandbox is the mechanism by which that could change.
Outlook
The pivotal forward marker for this module is the CHF-stablecoin sandbox's expected conclusion around the fourth quarter of 2026, which will determine whether Switzerland moves toward a binding, broadly-used regulated CHF stablecoin regime or whether the initiative remains a voluntary pilot without converting into a formal FINMA reserve/redemption requirement for issuers. Given the sandbox is bank-consortium-led rather than a solo fintech venture, the direction of travel favours eventual institutionalisation, but this cycle's evidence does not yet support treating that as settled. This module's amber status and Uncertain confidence rating are appropriately conservative pending that resolution, and the module should be revisited closely as the sandbox approaches its stated conclusion window.
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.
1 earlier distinct update(s)
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.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (3)
- T3 · CoinDeskStablecoin issuers (Switzerland) — a banking license by arranging a third-party bank 'default guarantee' to repay depositors, per FINMA guidance on the associated risks and safeguardsretrieved M4bindingin force
- T3 · CoinDeskFINMA — that stablecoin customers hold a direct claim against the guarantee-providing bank and that the default guarantee fully cover customer deposits plus accrued interestretrieved M4bindingin force
- T3 · CoinDeskConsortium of major Swiss banks (UBS, Sygnum, PostFinance, Raiffeisen, ZKB, BCV, Swiss Stablecoin AG) — a live sandbox in 2026 to test a regulated Swiss-franc stablecoin; Switzerland does not yet have a broadly-used regulated CHF stablecoin in forceretrieved M3non-binding