Stablecoins and Crypto Institutions: Where the Swiss FinIA Reform Stands

By Thomas Contin, Managing Partner

On 22 October 2025 the Federal Council opened a consultation on an amendment to the Financial Institutions Act (FinIA). It is the most significant change to Swiss crypto regulation since the DLT Act of 2021. The consultation closed on 6 February 2026, and the Federal Council has announced its dispatch to Parliament for the second half of 2026 at the earliest.

Two new licences

The draft abolishes the fintech licence introduced in 2019 under the Banking Act and replaces it with two categories in the FinIA. Payment instrument institutions may accept funds from the public without the current limit of CHF 100 million and issue stablecoins. Crypto institutions provide services with crypto-assets that are not financial instruments, such as trading, custody and exchange, under requirements inspired by those for securities firms but lighter.

Stablecoins

Under the draft, only a licensed payment instrument institution may issue a stablecoin pegged to a single currency. The issuer must hold the reserve assets segregated, so that holders are protected in bankruptcy, and must redeem the coins at their nominal value. The anti-money laundering duties in connection with issuance are also clarified.

The Swiss Bankers Association and other respondents criticised the rule that banks could issue stablecoins only through a separate payment instrument institution, and asked for clarity on deposit tokens. The dispatch will show whether the Federal Council follows them.

Supervision

Many providers that today only need to join a self-regulatory organisation would move under direct FINMA supervision. Transitional periods are planned, but businesses should expect authorisation procedures with capital, organisational and audit requirements.

What it means today

Until the reform enters into force, the current rules apply: the banking licence or fintech licence for accepting deposits, affiliation to an SRO for financial intermediaries under the Anti-Money Laundering Act, and FINMA's guidance on stablecoins. Projects that plan to issue a Swiss franc stablecoin or offer custody should design their structure now with the future licence in mind, to avoid having to rebuild it later.

Conclusion

The reform will give Switzerland a clear framework for stablecoins, comparable in ambition to MiCA but with its own approach. Advisorn follows the parliamentary process and helps crypto businesses assess which licence they will need and how to prepare for it.