VASP Services under SRO Regulations in Switzerland

The Swiss SRO Membership, often referred to as a “VASP licence” or “payment licence”, offers a simplified and flexible route into the regulated Swiss market for companies active in financial services, cryptoassets, and payments. Designed for agility, this model allows firms to operate under the Swiss Anti-Money Laundering Act (AMLA) — but without the overhead of direct FINMA supervision.

Especially attractive for virtual asset service providers and currency exchanges, the SRO regime has quickly become one of the most widely used and efficient setups in Switzerland.

What is the Swiss SRO Membership?

An SRO membership is a formal affiliation with a FINMA-recognised Self-Regulatory Organisation (SRO) such as VQF or SO-FIT. While SRO members are subject to ongoing supervision in relation to AML and CTF compliance, they are not directly supervised by FINMA itself. This distinction reduces complexity while maintaining regulatory credibility.

In practice, this setup is often referred to as a “crypto licence” or "VASP licence". It is already used by hundreds of Swiss companies to offer payment and crypto services — without requiring a full banking or fintech licence.

What services can be offered?

The SRO membership enables companies to operate a wide range of financial and crypto-related services within a regulated AML framework, including:

Currency Exchange Services: SRO members can exchange fiat-to-fiat, fiat-to-crypto, and crypto-to-fiat currencies, including ATM operations and FX platforms, without requiring a banking licence. (No financial instruments involved.)

Payment and Remittance Services: Companies can execute domestic and international payments, transfer funds on behalf of clients, and offer e-money issuance and payment facilitation services (under certain conditions).

Card Services (under certain conditions): SRO members may issue debit, credit, and prepaid cards, apply for their own BIN numbers, and act as intermediaries between clients and issuing/acquiring banks, providng POS/NFC terminal deployment.

Lending and Credit Services: Permissible services include leasing, commercial loans, crowd-lending, and credit card offerings, subject to certain regulatory limitations and requirements.

Precious Metals and Commodities Trading: Authorised to trade high-purity gold, silver, platinum, and palladium, either proprietary or client-based.

Custody and Wallet Services: Members may provide crypto custody solutions via segregated individualized wallets.

Crypto Exchange and Brokerage Services: Operation of centralised exchanges (CEX), execution of crypto-to-crypto and fiat-to-crypto trades, and provision of crypto brokerage and market-making services (no financial instruments/securities).

On/Off Ramp Solutions: Platforms for converting between fiat and crypto, serving both retail and institutional clients.

Crypto Remittance and Transfer Services: Allows the facilitation of crypto transfers for clients, including assistance in transferring crypto to a third party.

Public Deposit Handling: Companies may hold public deposits up to CHF 1 million under the sandbox regime, with exceptions allowing higher limits under defined transactional use cases.

How to become an SRO Member

The path to SRO membership follows a structured process, generally taking between 2 to 4 months depending on the chosen SRO and the complexity of services offered.

It begins with the incorporation of a Swiss legal entity, followed by the drafting of a business plan and strategy. Companies must define their compliance framework, select suitable KYC/AML technologies, and appoint a qualified AML Officer. An external AML auditor must also be designated before the application is finalised and submitted to the SRO.

After review and potential adjustments, the SRO issues its decision — and operations can begin. Compared to other regulatory paths, the SRO model offers a faster and more efficient go-to-market strategy.

Why choose the SRO Licence?

The Swiss SRO Membership strikes a balance between compliance and commercial agility. For startups and international firms alike, it provides the credibility of Swiss AML oversight without the complexity of full prudential regulation.

Companies benefit from a stable, innovation-friendly environment with one of the most advanced crypto ecosystems in the world. In addition, Switzerland offers a competitive tax regime — for example, a corporate tax rate as low as 11.85 % in the Canton of Zug.

For any business looking to combine crypto, payments, and cross-border financial services in a reputable jurisdiction, the Swiss SRO regime remains one of the most pragmatic and effective options available.