The Swiss fintech licence (sandbox and licence)
Over the years Switzerland has built a graduated path for those who want to raise funds from the public without becoming a bank in the full sense. Two instruments in particular define this space: the sandbox and the fintech licence. They are not the same thing, they do not cover the same models and they cannot be chosen at will: they depend on how much you raise, on what you do with the funds and on how your structure is organised. Let us look at how they work and when it makes sense to use them.
The problem they solve
The principle is simple: accepting deposits from the public is, as a rule, banking activity and requires a full banking licence, with very heavy capital and organisational requirements. For an early-stage project this is often prohibitive. The sandbox and the fintech licence create two intermediate steps that allow funds to be raised within precise limits, with burdens proportionate to the risk.
The sandbox
The sandbox allows deposits from the public to be accepted up to CHF 1 million without authorisation from the supervisory authority, under well-defined conditions:
- the funds are neither invested nor remunerated (no interest paid to depositors);
- clients are informed that the project is not subject to supervision and that the deposits are not covered by the deposit guarantee;
- one remains subject in any case to the anti-money-laundering rules where the activity requires it.
It is the instrument designed to test a model before scaling: you verify demand, build your client base, run in your processes. The CHF 1 million limit is a hard ceiling: exceeding it, or changing the nature of the activity, causes the exemption to fall away and brings the project back within the full authorisation perimeter.
The fintech licence
The fintech licence — the authorisation provided for by the Banking Act for institutions that do not carry out genuine banking activity — is one step above the sandbox. It allows deposits from the public to be accepted up to CHF 100 million, always on condition that such funds are neither invested nor remunerated. It is a lighter regime than the banking one, but it remains a genuine authorisation, with:
- minimum capital requirements proportionate to the activity;
- adequate organisation, control functions and risk management;
- persons meeting the requirements of fit-and-proper standing and guarantee of irreproachable business conduct;
- disclosure obligations towards clients.
It is the choice for models that have passed the testing phase and raise significant volumes, but that do not carry out classic banking intermediation (they do not transform maturities, they do not invest the deposits).
Sandbox, fintech licence and banking licence compared
Simplifying the three levels:
- Sandbox — up to CHF 1 million, no authorisation, funds neither invested nor remunerated, mandatory disclosure to clients.
- Fintech licence — up to CHF 100 million, authorisation with required capital and organisation, funds neither invested nor remunerated.
- Banking licence — no ceiling of that kind, but full requirements; needed if you invest or remunerate the deposits, or if you carry out genuine intermediation.
The decisive dividing line is not only the amount, but what you do with the funds: the moment you invest or remunerate them, the sandbox and the fintech licence are no longer enough.
The step that counts: qualifying the activity
The condition common to both instruments is that the funds remain “at rest”. Many models fail qualification not because of the amount, but because they envisage some form of return or use of the deposits that takes them outside the exemption perimeter. Before choosing the level you therefore need to map the flow of funds precisely: who pays in, on what basis, what happens to the money, how and when it comes back. It is this map, not the “fintech” label, that determines the applicable regime.
How SIH ONE approaches the topic
SIH ONE deals with structuring and advice: mapping the model, identifying the correct level (sandbox, fintech licence or a higher perimeter), designing the corporate and governance structure, setting up the anti-money-laundering safeguards. Where the activity requires an authorisation from the supervisory authority, the regulated activities are handled through authorised partners. The goal is that you know, before raising the first franc, which step you are on and what it entails.
This content is informational and does not constitute legal or regulatory advice. The framework evolves: every model must be verified in the specific case.
Are you weighing up whether the sandbox is enough or you need the fintech licence? Let’s talk: we map your fund-raising and identify the correct level, with the right partners where authorisation is needed.