FinIA Reform 2026: Stablecoins and Crypto Institutions

Key Takeaways

In October 2025, the Federal Council opened a consultation (concluded in February 2026) proposing two new licence categories: Payment Institutions and Crypto Institutions.
Payment Institutions are intended to replace the existing fintech licence under Art. 1b of the Banking Act, allowing the issuance and custody of Swiss stablecoins without the current CHF 100 million cap, backed by bank deposits or highly liquid assets.
Crypto Institutions are intended to receive a dedicated, FINMA-supervised regime for custody, trading and market-making of crypto assets and stablecoins – structurally modelled on securities firms, but with a lighter requirements profile.
These changes are proposals. A Federal Council dispatch is a submission to Parliament, not a final enacted statute.

What is the current starting point for stablecoins?

FINMA already clarified in its stablecoin guidance of 11 September 2019 that stablecoins, depending on their structure, may qualify as payment, asset or hybrid tokens, and can accordingly trigger different rules – from pure AMLA supervision to banking-law deposit regulation where a repayment guarantee exists. In practice, this case-by-case classification has created legal uncertainty, particularly for issuers seeking to issue stablecoins at scale with international reach.

What changes with the proposed "Payment Institution" category?

The new Payment Institution category is intended to replace the existing, but rarely used, fintech licence under Art. 1b of the Banking Act. Central to the proposal is the removal of the current CHF 100 million cap on publicly accepted funds. Payment Institutions would be permitted to issue and custody "Swiss stablecoins" backed by bank deposits or highly liquid, safe assets (HQLA) – an approach structurally reminiscent of, though not identical to, the coverage requirements for e-money tokens under the EU's MiCA regulation.

What is a "Crypto Institution" under the reform proposal?

Crypto institutions would receive a regime for services involving cryptobased assets with trading character. It draws on securities-firm rules while recognising that the covered assets are not financial instruments. Final legislation and implementing rules will determine the requirements; the proposal does not justify a blanket assumption that every requirement will be lighter.

The proposal also envisages AML changes. Final rules on transaction monitoring and technical control and blocking capabilities will determine implementation. Existing obligations continue until legally amended.

What is the current status and what happens next?

The consultation ran from 22 October 2025 to 6 February 2026. This article explains the published consultation proposal. SIF documents envisage a dispatch no earlier than the second half of 2026. A dispatch, parliamentary enactment and entry into force are distinct steps; final duties and deadlines must not be inferred from the consultation draft.

Frequently Asked Questions

Is the 2025/2026 FinIA reform already binding law?

No. The consultation has concluded, but a definitive enactment is still pending.

Does the new regime also apply to foreign stablecoin issuers with Swiss clients?

The proposed stable cryptobased means-of-payment category concerns certain stablecoins issued in Switzerland. Services involving foreign-issued stablecoins may instead fall within the proposed trading-character cryptoasset category. Foreign issuers and service providers therefore need separate analysis.

How does a Crypto Institution differ from an investment firm?

The planned regime draws on securities firms but concerns services with assets other than financial instruments. Whether individual requirements are lighter depends on the activity and final rules.

Do existing fintech licence holders (Art. 1b Banking Act) need to do anything?

Once the definitive enactment is available, a transition arrangement for existing licence holders is to be expected; details are currently still open.

How does the Swiss model differ from the EU's MiCA regulation?

MiCA is a separate EU legal framework. The Swiss proposal uses different categories and supervisory structures. Backing, redemption claims, disclosure and AML controls require a detailed comparison; equivalence or automatic market access does not follow.

Practical next steps

Companies looking to issue, custody or trade stablecoins should actively monitor the ongoing FinIA reform and align their business models with the anticipated new licence categories at an early stage.

Discuss your project

Martin Liebi advises companies on Swiss crypto regulation. Arrange an initial conversation.

Primary sources

Official sources for this article

SIF – FINIG / FinIA reform proposal2025-10-22 SIF – Stablecoin reform factsheet2025-10-22