Bern, 8 December 2025 – Switzerland has recently lost much of its initial lead in innovative financial technologies. The Swiss Blockchain Federation (SBF) therefore welcomes the Federal Council’s decision to revise the Financial Institutions Act (FINIG) to create competitive conditions for stablecoins. In its position paper published today, the SBF calls for a clear commitment to strengthening Switzerland’s financial center and presents concrete proposals.

The FINIG package, which entered consultation on 22 October 2025, comprises four elements:

• The Fintech license introduced in 2019 (Art. 1b BankG) will be transferred into FINIG as an authorization for payment institutions.
• The legal framework for stablecoins builds on this foundation.
• Collective custody of crypto assets and additional services will be covered by a new license for crypto institutions.
• Crypto services will be subject to similar due diligence obligations as financial service providers; transparency requirements will apply to public offerings of certain crypto assets and their admission to trading.

An SBF working group, in close collaboration with the Crypto Valley Association (CVA), the Swiss Fintech Association (SFTA), and the Capital Markets and Technology Association (CMTA), prepared the position paper. It acknowledges that the draft provides a sound basis for further developing the legal framework for payment and crypto services. At the same time, it identifies 14 areas requiring clarification and refinement and offers concrete recommendations.

A Missing Vision for the Financial Center of the Future

“The direction is right. The Federal Council shows that it takes the realities of the digital financial market seriously,” says Heinz Tännler, President of the SBF. “But the draft remains unclear in key areas. Without consistent guardrails and a clear vision, Switzerland risks falling behind in global competition.”

The position paper criticizes the lack of a strategic vision. The associations call for the draft to focus primarily on strengthening Switzerland’s competitiveness. Such a vision should build on Switzerland’s strengths, including:

• High legal certainty
• Advanced institutional integration of crypto business
• Strong tradition of self-regulation

The associations also emphasize that the global financial industry is undergoing a fundamental transformation. Innovative technologies such as artificial intelligence, distributed ledger technology (DLT), and digital identity are reshaping how financial services and products are created, distributed, and managed.

Stablecoins and tokenized bank deposits will become an integral part of future payment systems.

“Swiss law must facilitate these fundamental developments, not hinder them. It would be fatal if our country missed these opportunities due to regulatory hurdles,” says Hans Kuhn, Head of the SBF Working Group.

Positive Aspects and Key Concerns

The SBF welcomes the proposed strengthening of consumer protection for fintech startups and the removal of the cap on public deposits. At the same time, the associations warn against extending the regulatory perimeter of payment institutions to services previously outside prudential regulation or only subject to anti-money-laundering rules. These business models are critical and include payment services for retailers, gift or voucher systems, bonus/points/rebate programs, holiday and lunch-check systems, acquiring services, and numerous settlement solutions. There is no justification for prudential regulation of these models.

Stablecoin Issuance Finally Possible

The FINIG revision creates conditions that will finally allow stablecoins to be issued from Switzerland. Stablecoins are virtual currencies pegged to official currencies (e.g., USD or EUR) through a stabilization mechanism. They have grown explosively in the dollar market and are expected to play a central role in payment systems and financial markets globally.

The associations welcome measures to address money-laundering risks, such as blacklisting sanctioned addresses, but insist these rules must apply to all types of stablecoins. They strongly oppose limiting authorization to specific stablecoin models, as this would severely restrict innovation. They also criticize the requirement that banks issue stablecoins only through separate payment institutions, arguing that this lacks a sound rationale given banks’ central role in payments.

Less Restriction, More Risk-Based Regulation

The associations take a critical view of the proposed regulation for crypto institutions, which mirrors the framework for securities firms. Such an approach could lead to drastic market consolidation—similar to the EU, where full implementation of MiCAR reduced the number of crypto service providers from around 3,000 to just 150–300.

They propose a tiered regulatory system based on institutional significance: only large and systemically important institutions should fall under FINMA’s direct supervision, while smaller providers should be overseen by recognized supervisory organizations, as is the case for asset managers.

Urgent Need for Action at FINMA

Finally, the associations highlight the urgent need to improve FINMA’s licensing procedures, which are currently too slow and opaque. Without such improvements, the new regulation risks being ineffective. They propose that licensing decisions should normally be completed within six months of submitting a complete application.

“We need rules that are technology-neutral, risk-appropriate, and internationally compatible—and a FINMA that implements them reliably and transparently,” says Hans Kuhn.

The 14 Key Recommendations of the SBF Working Group

The following 14 points summarize the areas where the expert group sees the greatest need for adjustment. They aim to ensure legal certainty, avoid duplication, correct impractical elements, and prevent innovation from being stifled by unnecessary regulatory hurdles.

1. Clarify whether the regulatory perimeter for payment institutions extends beyond the current fintech license. The associations strongly oppose including payment services previously outside prudential regulation.
2. Maintain a strictly risk-based approach for payment institutions, which primarily face operational risks.
3. Allow banks to issue stablecoins directly without creating separate entities.
4. Preserve the ability to issue other payment tokens under existing exemptions.
5. Define the interest ban more precisely to allow non-interest revenue models.
6. Ensure coverage requirements remain practical, including access to SNB accounts.
7. Establish clear legal foundations for AML practices such as blacklisting.
8. Avoid applying the securities firm model to crypto institutions; adapt rules to their specific risks.
9. Focus the perimeter on custody; do not automatically require licenses for trading or market-making.
10. Introduce a two-tier supervisory system: FINMA for large institutions, SROs for smaller ones.
11. Limit due diligence obligations to crypto assets with investment characteristics.
12. Clarify and broaden the whitepaper requirement to enhance transparency without triggering prospectus duties.
13. Drop consolidated supervision for foreign holdings, which would deter investment.
14. Make FINMA licensing faster and more predictable, with clear criteria and deadlines.

The full position paper on the FINIG revision is available here.