FINMA Authorisation & Licensing Support in Switzerland
ComplyFactor helps financial businesses assess the FINMA authorisation route that may apply to their activities and prepare the governance, controls, documentation and application work needed for licensing readiness.
How ComplyFactor Supports FINMA Authorisation Readiness
FINMA authorises and supervises a range of Swiss financial institutions. Choosing the wrong regulatory route can create avoidable application work, delays and remediation later in the process. ComplyFactor helps financial businesses work out whether FINMA authorisation is likely to apply to their activities, identify the licensing route that fits, and prepare the governance, controls, documentation and application work that route requires, from an initial perimeter assessment through to submission-ready application material.
This includes fintech companies, payment businesses, portfolio managers, trustees, and other financial intermediaries entering or expanding in Switzerland.
This service sits alongside ComplyFactor's wider AML & Regulatory Compliance Services in Switzerland. Where a business's activity points toward SRO affiliation rather than FINMA licensing, see our SRO Affiliation Support service instead.
Does Your Business Need FINMA Authorisation?
Not every financial intermediary follows the same route. Some businesses require direct FINMA authorisation, some require a FINMA licence with ongoing supervision by a Supervisory Organisation (SO), and some instead fall under the SRO affiliation route under the AMLA, or outside any licensing requirement altogether, depending on their activities and applicable exemptions.
A company's name or marketing label does not decide this. What matters is what the business actually does: custody or control of client assets, discretionary management, deposit-taking, securities activity, fiduciary or trust activity, payment flows, digital-asset services, client type, product structure and group structure all factor into the assessment.
A Simplified Routing Guide
Regulatory classification depends on the specific facts, activity, structure and applicable exemptions. This table is a simplified routing aid, not a legal determination.
Illustrative routing only — the applicable path depends on the specific facts, not a fixed sequence every business follows.
FINMA Licensing Support for Portfolio Managers and Trustees
A portfolio manager manages client assets on a commercial basis in the name of and on behalf of clients under an appropriate mandate, or manages the assets of collective investment schemes or occupational pension funds below the defined thresholds. A trustee manages or disposes of a separate fund on a commercial basis for the benefit of a beneficiary or a specified purpose under the instrument creating a trust.
For both portfolio managers and trustees, commercial activity can arise through the earnings or business-relationship tests. A third asset-based test also applies, but its formulation differs by activity: for portfolio managers it concerns unlimited power of disposal over third-party assets exceeding CHF 5 million at any given time, while for trustees it concerns trust funds managed exceeding CHF 5 million at any given time.
Earnings
Gross earnings exceeding CHF 50,000 per calendar year — same test for both categories.
Business Relationships
More than 20 contractual partners per calendar year, not limited to a one-off activity — same test for both categories.
Asset-Based Test
Portfolio manager: unlimited power of disposal over third-party assets exceeding CHF 5m.
Trustee: trust funds managed exceeding CHF 5m.
ComplyFactor helps assess whether either route applies to a business, prepares the readiness work FINMA and the selected SO will expect, and supports the application through to submission.
We Assess Licensing Readiness Before the Application Is Filed
Before an application goes anywhere near FINMA or an SO, ComplyFactor reviews the areas most likely to raise questions. The aim is to find and close gaps before submission, not after.
We Help Prepare the Governance, Controls and Documentation FINMA Expects
FINMA licensing requires more than a completed form. Portfolio managers and trustees must be domiciled in Switzerland, be suitably organised, and provide adequate financial guarantees. Members of the body responsible for management, and of the body responsible for governance, supervision and control, must be able to provide a guarantee of irreproachable business conduct, enjoy a good reputation, and hold the required professional qualifications.
Governance
Organisational rules, management and ownership disclosures, and fitness-and-propriety evidence.
Controls
Risk-management framework and internal controls sized to the business's actual activity.
Documentation
The supporting material FINMA and the SO will review as part of the application.
From Regulatory Perimeter to FINMA Application Readiness
ComplyFactor's FINMA licensing engagements generally follow the same structure, scoped to what a business actually needs.
Business Model & Regulatory-Perimeter Assessment
Licence Category / Route Assessment
Readiness Gap Review
Governance & Control Preparation
Application Documentation
Submission / Regulator-Response Readiness
Post-Authorisation Compliance Planning
The FINMA Application Process for Portfolio Managers and Trustees
FINMA's licensing process for portfolio managers and trustees runs entirely through its electronic Survey and Application Platform (EHP), in five stages.
Illustrative workflow — not the FINMA EHP interface.
ComplyFactor supports readiness, information-gathering, documentation and review at each of these stages. ComplyFactor does not control how long FINMA or the SO take to review an application, does not hold or access the EHP as the applicant's own registered account, and cannot determine or guarantee the outcome of an application.
FINMA Licensing and SO Supervision Are Different Roles
FINMA
Supervisory Organisation (SO)
Domestic group companies under consolidated FINMA supervision can be an exception to the normal SO-supervision model. Keeping the two roles distinct helps structure the licensing workstream correctly from application through ongoing supervision.
Existing FINMA-Licensed Firms May Need Support With Licence-Relevant Changes
Licensing does not end at authorisation. Portfolio managers and trustees must inform their SO in advance of changes affecting their licence, and significant changes require FINMA's prior approval.
Organisational / Partnership
Documents
Change of Supervisory
Organisation
Management / Business-Operations Personnel
Ceasing licensed activity also requires FINMA's prior approval, with the SO asked to give its opinion beforehand. This is a distinct requirement, not simply one example on the significant-change list above. ComplyFactor helps assess whether a planned change is significant, prepares the supporting documentation, and readies the notification or approval request for the SO and FINMA.
What You Can Receive From a FINMA Licensing Readiness Engagement
Deliverables depend on the agreed scope. A typical engagement can include:
Not every engagement automatically includes every item above.
Why Work With ComplyFactor on FINMA Authorisation Readiness?
Regulatory Route Clarity
Identifying the correct licensing path before building an application around the wrong one.
Practical Governance & Controls
Turning requirements into practical documentation, not generic policy templates.
Application Documentation Readiness
Supporting material prepared for what FINMA and the SO will actually review.
Cross-Border Fintech & Payments Context
Experience with fintech, payments and financial-intermediary structures.
ComplyFactor is not FINMA, not a FINMA-authorised Supervisory Organisation, not an SRO, and not a Swiss law firm. ComplyFactor cannot guarantee that a business will obtain FINMA authorisation and does not control FINMA's or an SO's review timeline or decisions. Where the applicable licensing perimeter or a legal interpretation requires a formal Swiss legal opinion, ComplyFactor can identify the issue, but qualified Swiss legal counsel should provide that opinion.
Frequently Asked Questions
Can ComplyFactor submit a FINMA licence application for my company?
ComplyFactor supports preparation, readiness and documentation throughout the process. Formal submission runs through the applicant's own FINMA Survey and Application Platform (EHP) account and the selected SO's confirmation step; ComplyFactor does not submit as though it were the applicant's own registered account holder.
How can I check whether a company is authorised by FINMA?
FINMA publishes an official directory of authorised institutions, individuals and products. Checking that directory is different from preparing a new licence application, and being listed there does not indicate anything about a separate applicant's own readiness.
How long does FINMA authorisation take?
There is no single universal timeline. Duration depends on the licence category, how complete and well-prepared the application is, the complexity of the business, the SO review stage where applicable, and how many follow-up questions FINMA or the SO raise.
Can the same business require both a portfolio-manager licence and a trustee licence?
Yes. Portfolio management and trustee activity are licensed separately. If a trustee also carries on portfolio-management activity that meets the licensing test, or a portfolio manager also acts as a trustee, an additional FINMA licence is required for that second activity.
Does every Swiss fintech need a FINMA FinTech licence?
No. The applicable route depends on the actual business model and regulated activity. Depending on the facts, a fintech business may need a FinTech licence under Article 1b of the Banking Act, another FINMA licence, SRO affiliation, or no specific authorisation at all.
What happens if FINMA or the SO requests additional information after submission?
FINMA or the selected SO may request additional information during the review process. ComplyFactor can help organise supporting evidence and prepare responses, but cannot control whether, when or how often further information is requested.
Discuss Your FINMA Authorisation Requirements
Whether you are assessing if FINMA authorisation applies to your business, preparing a portfolio-manager or trustee application, or getting ready for a licence-relevant change, ComplyFactor can help map the applicable route and build a practical licensing workstream.