Switzerland — License Map

Switzerland is the jurisdiction where crypto regulation was built into the law rather than bolted on afterward. The Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology (the "DLT Act"), which entered into force between February and August 2021, amended ten existing federal laws to accommodate blockchain-based assets within a coherent legal framework. FINMA, as the sole integrated financial regulator, supervises all crypto activities -- custody, stablecoin issuance, trading, and settlement -- through a tiered licensing model that scales from a CHF 1 million regulatory sandbox to full banking authorisation. The result is a regime that offers statutory bankruptcy protection for custodied crypto assets (a global rarity), a pragmatic pathway for stablecoin issuance through bank default guarantees, and a proposed reform that would create dedicated crypto institution and payment institution licences. The FinIA reform consultation closed on 6 February 2026; the Federal Council was still evaluating responses as of June 2026, with a dispatch to Parliament expected in the second half of 2026 at the earliest and entry into force no earlier than 2027 (some practitioner analyses suggest 2028).

1. Regulatory Architecture

FINMA (Swiss Financial Market Supervisory Authority) is the single regulator for all financial market activities, including both crypto custody and stablecoin issuance. Unlike jurisdictions where multiple agencies compete for authority (the United States) or where standalone crypto legislation creates parallel regimes (the EU under MiCA), Switzerland integrates crypto regulation into its existing financial market statutes and lets FINMA interpret and enforce them.

Primary legislation across both activities:

The tiered licensing model:

Switzerland does not force every crypto operator into a single licence category. Instead, it offers a graduated structure where regulatory burden scales with the risk and scope of the activity:

The FinTech licence is scheduled for replacement under the proposed FinIA reform (see Section 7). BX Digital AG received the first DLT trading facility licence from FINMA on 12 March 2025 (legally effective 14 May 2025), demonstrating the operational viability of this category. At its 21 April 2026 annual media conference, FINMA confirmed that BX Digital remains the sole DLT trading facility licensee (classified as a small DLT trading facility) and named its initial trading participants: Hypothekarbank Lenzburg, Sygnum, InCore Bank, ISP Group, and Euwax.

Key FINMA guidance instruments:

2. Activity Comparison Table

3. Multi-Activity Licensing

Switzerland's tiered framework allows firms to combine custody and stablecoin activities through several structural approaches. The regime does not force operators into single-activity silos -- but the combination requires careful licence selection.

DLT trading facility as a combined vehicle:

The DLT trading facility licence under FMIA is the most natural multi-activity licence in Swiss law. It permits multilateral trading, settlement, and custody of DLT securities under a single authorisation. A firm operating a DLT trading facility could provide custody of tokenised stablecoins as DLT securities while simultaneously operating the trading infrastructure. BX Digital AG and SIX Digital Exchange (SDX) illustrate different scales of this model -- BX Digital as the first standalone DLT facility licensee, SDX as a full digital financial market infrastructure with exchange and central securities depository licences.

Banking licence as the universal vehicle:

A full banking licence permits both custody (as segregated custody assets under Art. 16 No. 1bis BA) and deposit-taking (which covers stablecoin issuance). Sygnum Bank and AMINA (formerly SEBA Bank) operate under this model, combining institutional crypto custody with stablecoin-related services. Sygnum issues the Digital CHF (DCHF), backed by Swiss National Bank sight deposits, while providing institutional custody -- both under a single banking licence.

FinTech licence with default guarantee:

A FinTech licensee can accept deposits up to CHF 100 million (including crypto-based assets) and provide custody services. If the same entity or a related entity relies on the default guarantee exemption for stablecoin issuance, both activities can coexist -- though the CHF 100 million cap constrains scale.

Proposed FinIA reform -- structural separation:

The October 2025 consultation (closed 6 February 2026; responses under evaluation as of June 2026) proposes two new licence categories that would replace the FinTech licence:

• Payment Institutions -- exclusively authorised to issue Regulated Stablecoins; client deposits up to CHF 5 billion; enhanced prudential safeguards (the explanatory report removes the FinTech licence's CHF 100M cap and substitutes client-fund segregation plus "stricter capital, liquidity and resolution rules" — but no fixed CHF minimum-capital figure is set in the draft law)
• Crypto Institutions -- custody, trading, exchange, and staking for crypto assets with trading characteristics; lighter than securities firm requirements; direct FINMA supervision (capital and organisational requirements are "modelled on" the securities-firm regime but, per the explanatory report, are to be "tailored to crypto-assets and proportionately reduced" at the ordinance level — so no specific CHF threshold is published yet)

Critically, the proposed framework would require banks to establish a separate legal entity to issue Regulated Stablecoins. A group seeking to combine custody and stablecoin issuance would therefore operate two entities: a Crypto Institution for custody and trading, and a Payment Institution for stablecoin issuance. This mirrors the structural separation approach Singapore's MAS imposes on SCS issuers, though the Swiss version emerges from a different rationale (deposit protection rather than activity restriction).

4. The DLT Act Advantage

The DLT Act's amendments to the Debt Enforcement and Bankruptcy Act (DEBA) are the single most important feature distinguishing Switzerland from virtually every other jurisdiction for crypto custody. They provide statutory certainty that most jurisdictions -- including the United States, the United Kingdom, and the EU under MiCA -- have not achieved.

Article 242a DEBA -- Segregation of crypto-based assets in bankruptcy:

Crypto-based assets held by a custodian can be segregated from the custodian's bankruptcy estate (excluded from general creditor claims) when three conditions are met:

1. The custodian has exclusive actual power of disposal over the assets
2. The debtor is obligated to have the assets readily available for the client at all times ("constant readiness" / jederzeitige Verfugbarkeit)
3. The assets can be assigned to that client -- individually (separate wallet per client) or pro rata in collective custody with clear share allocations

When these conditions are met, the client's crypto assets are returned in-kind, not as a monetary claim against the bankruptcy estate. This is a fundamentally different outcome from jurisdictions where custodied crypto may become part of an insolvent entity's general pool.

Article 242b DEBA -- Data segregation:

Clients of a bankrupt custodian can claim access to the data needed to identify and recover their assets. This closes the information gap that could otherwise prevent effective asset recovery even where legal segregation exists.

Ledger-based securities (Registerwertrechte):

The DLT Act created a new category of securities that exist natively on a blockchain. Rights -- including membership rights, claims, and copyrights -- can be tokenised and transferred via private key transactions with full legal recognition. This gives tokenised stablecoins structured as DLT securities a legal foundation that does not depend on analogies to existing paper-based instruments.

What this means for multi-activity operators:

A firm providing both custody and stablecoin-related services benefits from:

• Legal certainty for custodied assets -- client tokens are protected by statute, not just by contract or regulatory guidance
• Reduced counterparty risk -- institutional clients can verify that Swiss custody arrangements provide bankruptcy protection equivalent to or stronger than traditional securities custody
• Tokenisation infrastructure -- stablecoins structured as ledger-based securities gain the full legal protections of the DLT framework, including transferability and enforceability

Comparative advantage:

5. Banking Access

Switzerland's "Crypto Valley" centred on the canton of Zug hosts a concentration of crypto-native banks and crypto-friendly traditional banks that is unmatched in Europe. Banking access for licensed crypto firms is significantly more straightforward than in most jurisdictions.

What makes Swiss banking access distinctive:

• Crypto-native banks exist: Sygnum and AMINA were purpose-built for digital assets and hold full FINMA banking licences. They do not merely tolerate crypto clients -- crypto is their core business
• SNB sight deposit backing: Both Sygnum (DCHF) and SDX (tCHF) back their Swiss franc stablecoins with deposits at the Swiss National Bank. This is the highest-quality reserve backing available globally
• Traditional banks have adopted crypto: Hypothekarbank Lenzburg, PostFinance, and Maerki Baumann demonstrate that crypto services are becoming part of mainstream Swiss banking
• No de-banking problem: Unlike the United States (Operation Chokepoint 2.0 concerns) or the United Kingdom (where crypto firms report banking access difficulties), Swiss crypto firms with proper licensing or SRO membership generally obtain banking relationships without systemic friction

6. Total Cost: Multi-Activity Operation

For a firm seeking to operate both custody and stablecoin issuance from Switzerland:

Year Zero (Setup)

Capital Requirements

Annual Ongoing

Total first-year cost for dual operation (FinTech licence path): approximately CHF 1.1M - CHF 2.8M.

Total first-year cost for dual operation (DLT facility path): approximately CHF 5.8M - CHF 7.2M.

The FinTech licence path is the lowest-cost entry point but carries the CHF 100 million deposit cap and will be replaced by the proposed Payment Institution / Crypto Institution framework. The DLT trading facility path costs more upfront but provides uncapped operations and integrated trading/settlement/custody capabilities.

7. Regulatory Direction

Switzerland is on a consolidation and upgrading trajectory -- replacing the fragmented FinTech/SRO landscape with dedicated licence categories under direct FINMA supervision.

Near-Term (2026-2027)

• FinIA reform enactment: The proposed Payment Institution and Crypto Institution licence categories would replace the FinTech licence. The consultation closed on 6 February 2026; the Federal Council must still publish a consultation report and submit a dispatch (Botschaft) and draft bill to Parliament, expected in the second half of 2026 at the earliest. Entry into force is therefore no earlier than 2027 (some practitioner analyses cite 2028), with a transition period for existing firms. As of June 2026 this remains a closed consultation proposal, not enacted law. Stablecoin issuance becomes exclusively reserved for Payment Institutions (banks must establish separate entities). Crypto custody, trading, and staking move to the Crypto Institution licence with lighter-than-securities-firm requirements but full FINMA supervision
• AML supervision transfer: AML compliance supervision shifts from SROs to direct FINMA oversight for both new licence categories, eliminating the intermediary layer
• OECD CARF implementation: Crypto-asset reporting to the Swiss Federal Tax Administration begins 1 January 2027 following the National Council's November 2025 postponement decision. First data exchanges with partner jurisdictions expected around 2028
• Basel Committee crypto banking rules: Switzerland is expected to transpose the Basel standards on crypto-asset exposures as they are finalised, applying them through the Capital Adequacy Ordinance

Strategic Signals

• FINMA Guidance 01/2026 signals a tightening of custody standards -- requiring prudentially supervised custodians (Swiss or foreign-equivalent) and mandating foreign custody equivalence assessments. The transitional tolerance for SRO-supervised custodians will end as the new licensing framework takes effect
• Structural separation for stablecoins: The requirement for banks to establish separate legal entities for stablecoin issuance adds operational complexity but strengthens depositor protection through ringfencing
• CHF 5 billion deposit cap for Payment Institutions: A dramatic increase from the current FinTech licence's CHF 100 million cap, signalling FINMA's expectation that Swiss stablecoin issuance will scale significantly. The minimum-capital figures for both new licences are deliberately NOT fixed in the draft FinIA text — they are delegated to a future implementing ordinance (Crypto Institution requirements "modelled on" the securities-firm regime then proportionately reduced; Payment Institution subject to "stricter capital, liquidity and resolution rules" with client-fund segregation replacing the deposit cap). No published CHF threshold exists as of June 2026
• Project Guardian participation: FINMA is an international partner in MAS's Project Guardian tokenisation initiative, alongside the UK's FCA and Japan's FSA, signalling alignment on cross-border tokenisation standards
• Sharper consumer-protection tone (FINMA Annual Report 2025, 21 April 2026): For the first time the crypto section was framed under FINMA advocating "appropriate consumer protection in crypto regulation," warning that consumers take on significant risks when buying, trading and transferring crypto. Enforcement activity rose to 55 concluded proceedings in 2025 (from 38 in 2024), ~450 investigations into potentially unauthorised activity, and 300+ warning-list entries -- signalling that licence applicants and existing operators face intensified supervisory scrutiny
• Bank-led stablecoin experimentation: The 8 April 2026 joint CHF stablecoin sandbox (UBS, PostFinance, Sygnum, Raiffeisen, ZKB, BCV + Swiss Stablecoin AG) tests a Swiss-franc stablecoin below the CHF 1 million sandbox-exemption threshold, ahead of the proposed Regulated Stablecoin licensing regime; participant roster is per the consortium's own announcement

Regulatory Timeline

The pattern: Switzerland built the legal foundation early (DLT Act, 2021), layered supervisory guidance on top (2024-2026), and is now restructuring the licence framework to reflect the maturity of the market. The direction is toward more direct FINMA supervision, dedicated licence categories, and higher standards -- but within a framework that remains more accessible and legally certain than most competing jurisdictions.

8. Tax Reporting Obligations

Switzerland's tax treatment of crypto assets is one of the most favourable globally for individual investors, though several reporting obligations apply to both individuals and service providers.

Key tax characteristics for crypto activities:

• No capital gains tax on private crypto investment -- individual investors who meet the five safe-harbour criteria (holding period, transaction volume, capital gains proportion, no leverage, hedging-only derivatives) hold crypto as tax-exempt private property. Capital gains on disposal are not subject to income tax at either the federal or cantonal level
• Professional traders taxed on gains as business income -- taxpayers classified as professional securities dealers (gewerbsmassiger Wertschriftenhandler) are subject to ordinary income tax rates (combined effective rate 20%-45%+) plus OASI/AHV social security contributions (~10%)
• Cantonal wealth tax applies to crypto holdings -- all crypto assets must be declared at their 31 December fair market value using ESTV official valuation lists (Kursliste). Wealth tax rates vary by canton, generally between 0.15% and 1% of net wealth
• Mining, staking, and lending income always taxable -- regardless of private or professional investor status, income from mining, staking, airdrops received for services, salary paid in crypto, and crypto lending interest is subject to income tax at fair market value on receipt
• VAT exempt -- the exchange of crypto for fiat or other crypto is exempt from VAT, analogous to the EU Hedqvist principle

CARF reporting (from 2027):

• Switzerland has committed to implementing the OECD CARF (Crypto-Asset Reporting Framework)
• From 1 January 2027: crypto platforms must collect and report data on Swiss users to the Swiss Federal Tax Administration (ESTV)
• First automatic exchanges expected around 2028, covering 2027 transaction data
• The Swiss Federal Council has proposed exchange of crypto information with 74 jurisdictions, including all EU member states, the UK, and most G20 countries (excluding the US and Saudi Arabia)
• Implementation was originally planned for 2026 but was delayed to 2027 by the National Council's November 2025 decision

FINMA-licensed crypto service providers are the entities that will serve as reporting entities under CARF, aligning tax reporting obligations with the existing licensing framework (FinTech licence, DLT trading facility licence, banking licence, or SRO membership).

9. RWA / Security Token Platform Licensing

Switzerland's DLT Act provides one of the most coherent frameworks globally for tokenized real-world assets. The DLT trading facility licence under FMIA is designed specifically for platforms that trade, settle, and custody DLT securities (ledger-based securities under the Swiss Code of Obligations). Switzerland also allows tokenized securities to be issued as DLT securities (registered uncertificated securities on a DLT register) under CO Art. 973d--973i.

9.1 License Details

9.2 Requirements

9.3 Application Process

Pre-application consultation with FINMA is recommended (contact: fintech@finma.ch). Duration depends on project complexity and application completeness. Fees governed by the Fees and Levies Ordinance (FINMA-GebV). An audit by an approved audit firm must be submitted before licensing. Ongoing supervisory monitoring after licensing.

9.4 Ongoing Obligations

• Ongoing FINMA supervisory monitoring
• Annual audit by FINMA-approved audit firm
• AMLA compliance (AML/KYC, Travel Rule)
• Business continuity management
• Reporting obligations to FINMA

9.5 Passporting

None. Switzerland is non-EU and has no MiCA equivalence agreement. Swiss-licensed entities cannot passport into the EU or EEA. Cross-border services require separate authorization in each jurisdiction.

9.6 Banking Access

Swiss crypto banks (Sygnum Bank, AMINA/SEBA Bank) provide integrated custody, trading, and tokenization services under banking licences. Bank Frick (Liechtenstein) also serves Swiss-based tokenization platforms. The DLT trading facility licence provides institutional credibility that facilitates banking relationships.

9.7 Key Holders

9.8 Transition

The October 2025 FinIA reform consultation proposes two new licence categories to replace the FinTech licence: a dedicated crypto institution licence and a payment institution licence. These would provide more tailored capital requirements and regulatory obligations for tokenized asset platforms. The consultation closed on 6 February 2026; with a Federal Council dispatch to Parliament expected in the second half of 2026 at the earliest, entry into force is not expected before 2027 (some analyses suggest 2028).

See

DeFi Protocol Licensing

Regulatory Approach

Switzerland applies a "substance over form" approach to DeFi regulation. FINMA does not have a DeFi-specific license; instead, it assesses the actual economic function of a protocol and applies the existing tiered licensing model accordingly. If a DeFi protocol performs functions equivalent to a bank, exchange, or custodian, it requires the corresponding license. The DLT Act provides the legal infrastructure for DeFi by recognizing ledger-based securities and DLT trading facilities.

The Swiss Foundation is widely used as a DAO legal wrapper, providing a recognized legal entity structure for decentralized protocol governance while preserving FINMA's ability to supervise the underlying activity.

Available License Types

DeFi-Specific Requirements

• Smart contract audits: FINMA expects DeFi operators to conduct independent smart contract audits as part of operational risk management. Guidance 01/2026 includes crypto-specific risk framework requirements applicable to DLT-based services.
• Governance framework: The Swiss Foundation structure is the standard DAO wrapper. FINMA requires identifiable responsible persons and a compliance function regardless of the protocol's governance model. The foundation board must have Swiss-resident members.
• "Substance over form" assessment: FINMA looks through the legal structure to the economic reality. A protocol marketed as "decentralized" but controlled by an identifiable team will be assessed based on its actual control structure, not its marketing.
• Bankruptcy protection: DEBA Articles 242a-242b provide statutory segregation of custodied crypto-assets from the custodian's bankruptcy estate -- a global rarity that applies to DeFi protocols holding user assets under a FINMA-licensed structure.
• FinIA reform (October 2025 consultation): Proposes a dedicated crypto institution licence and payment institution licence to replace the FinTech licence. These would provide more tailored capital requirements and regulatory obligations for DeFi protocol operators. The consultation closed on 6 February 2026; with a Federal Council dispatch to Parliament expected in the second half of 2026 at the earliest, entry into force is not expected before 2027 (some analyses suggest 2028).

Key Licensed Operators (DeFi-Adjacent)

Application Timeline

• Sandbox: Immediate (no FINMA supervision; CHF 1M limit)
• FinTech licence: 6--12 months
• DLT trading facility: Complex; pre-application consultation with FINMA recommended
• Banking licence: 12+ months; highly selective
• Proposed crypto institution licence: Entry into force no earlier than 2027 (consultation closed 6 February 2026; some analyses suggest 2028)

Cross-Reference

See

Sources: FINMA Guidance 01/2026, Crypto Custody Risk Framework (January 2026); DLT Act, Federal Assembly; FINMA FinIA Reform Consultation (October 2025)

Insurance / Risk Transfer Licensing

Overview

Switzerland applies a technology-neutral approach to insurance regulation -- there is no crypto-specific insurance mandate for custodians or other crypto service providers. FINMA supervises insurers under the Insurance Supervision Act (VAG), and the same licensing requirements apply regardless of whether the insured risk involves traditional or digital assets. The esisuisse deposit protection scheme (CHF 100,000 per depositor at banks) does not extend to crypto-asset holdings, even for FINMA-licensed custodians operating under a banking or FinTech licence.

Regulatory Authority

Insurance Requirements for Crypto Businesses

Insurance Provider Landscape

Switzerland's insurance sector (Swiss Re, Zurich Insurance Group) is among the world's most sophisticated, but digital asset insurance capacity is primarily accessed through Lloyd's and London market placements rather than domestic Swiss carriers.

Regulatory Direction

• The proposed FinIA reform (Payment Institution and Crypto Institution licences) does not include insurance mandates; Switzerland's preference remains statutory segregation over insurance
• FINMA Guidance 01/2026 tightened custody risk standards but did not introduce insurance requirements
• The proposed CHF 5 billion deposit cap for Payment Institutions may prompt consideration of additional protection mechanisms, though insurance is not currently part of the proposal

Cross-Reference

See

NFT & Digital Collectibles

Payment / Transfer Service Licensing

Overview

Switzerland does not have a standalone payment institution licence. Crypto payment services are regulated through FINMA's tiered licensing model, with a proposed dedicated payment institution licence under the FinIA reform (consultation closed 6 February 2026; entry into force not expected before 2027, some analyses suggest 2028).

Stablecoin payment issuance requires either a FinTech licence (CHF 100M deposit cap) or a banking licence (Basel III). The October 2025 FinIA reform consultation proposes that only licensed Payment Institutions may issue Regulated Stablecoins, with banks required to establish separate legal entities.

See

10. For Full Details

• Switzerland Crypto Payment Regulation -- FinTech licence, proposed Payment Institution licence, stablecoin issuance, AMLA obligations
• Switzerland Custody Regulations -- DLT Act bankruptcy protection, FINMA Guidance 01/2026, tiered licensing, DEBA Articles 242a-242b, key management standards, foreign custody equivalence
• Switzerland Stablecoin Regulations -- FINMA Guidance 06/2024, default guarantee exemption, reserve requirements, AML/KYC for stablecoin issuers, proposed Payment Institution licence, Swiss franc stablecoin projects (DCHF, tCHF, Frankencoin)
• Switzerland Digital Asset Taxation -- private capital gains exemption, five safe-harbour criteria for private investor status, cantonal wealth tax, ESTV valuation lists, CARF implementation timeline, professional trader classification
• Switzerland RWA Regulation -- DLT Act framework, DLT trading facility licensing, DLT securities (CO Art. 973d--973i), BX Digital AG, SDX, FinIA reform proposals
• Switzerland DeFi Regulation -- FINMA "substance over form" approach, DLT Act, Swiss Foundation DAO wrapper, crypto institution licence proposal, tiered licensing, DEBA bankruptcy protection
• Switzerland Digital Asset Insurance -- technology-neutral approach, esisuisse exclusion, DEBA bankruptcy protection as alternative, voluntary insurance market
• Switzerland NFT & Digital Collectibles -- SRO membership, FINMA substance-over-form approach, proposed Crypto Institution licence, AMLA scope for payment/investment NFTs

Related coverage

Switzerland — License Map in other research domains:

• DeFi Regulation & Liability Frameworks
• Digital Asset Insurance & Risk Transfer
• Digital Asset Taxation
• Institutional Crypto Custody Regulations
• NFT & Digital Collectibles Regulations
• Payment Services & Crypto Payment Regulation
• Stablecoin Regulations & License Regimes
• Tokenized Real-World Assets (RWA) Regulation

Verification Notes

Refresh 4 June 2026 (Correction Protocol applied): Reconciled every licence type, regulator, fee, capital, bond, timeline and effective-date against the refreshed Switzerland source-domain files (crypto-custody, stablecoin-regulations, crypto-payment-regulation, rwa-regulation, defi-regulation, digital-asset-taxation, digital-asset-insurance, nft-digital-collectibles — all modified 2026-06-04). Cost and timeline figures throughout this file (setup CHF, annual ongoing CHF, "6–12 months" application timelines) are self-reported / estimated practitioner ranges, not official FINMA fee schedules, and should be treated as indicative.

Corrections made:

1. FinIA reform timeline softened (multiple sections). Previously stated "expected entry into force late 2026 or early 2027" throughout. The refreshed crypto-payment-regulation, stablecoin-regulations and rwa-regulation source files establish that the consultation closed 6 February 2026; the Federal Council must still publish a consultation report and submit a dispatch (Botschaft) + draft bill to Parliament (expected H2 2026 at the earliest), making entry into force no earlier than 2027 (some practitioner analyses cite 2028). As of 2026-06-04 this remains a closed consultation proposal, not enacted law. Corrected in the intro, Sections 3, 7, 9.8, the DeFi section, the NFT section, and the Payment / Transfer Service section. Sources: Loyens & Loeff — FinIA Reform; Bär & Karrer — legislative process.

2. FinTech licence holder count corrected from "five (end-2024)" to "four (early 2026)". FINMA revoked one FinTech authorisation, reducing active holders to four: Bivial AG, Relio AG, SR Saphirstein AG, Yapeal AG. Corrected in the Activity Comparison Table and the Payment / Transfer Service section. Source: refreshed crypto-payment-regulation and rwa-regulation source files (FINMA data via Loyens & Loeff).

3. BX Digital AG licence detail refined. Licence granted 12 March 2025, legally effective 14 May 2025; FINMA confirmed at its 21 April 2026 annual media conference that BX Digital remains the sole DLT trading facility (a small DLT trading facility), naming its initial trading participants (Hypothekarbank Lenzburg, Sygnum, InCore Bank, ISP Group, Euwax). Source: FINMA — Annual Media Conference 2026 (21 April 2026); FINMA — First DLT trading facility licence (18 March 2025).

4. Cross-domain wikilink prefix fixed. All cross-domain wikilinks were missing the required deep-research/ path prefix (a pre-existing defect; basenames are ambiguous across domains). Added the prefix to align with peer license-map jurisdiction files.

New developments added (2026-03-20 → 2026-06-04 window):

• FINMA Annual Report 2025 (published 21 April 2026): sharper consumer-protection framing of crypto; 55 enforcement proceedings concluded (up from 38 in 2024); ~450 investigations into potentially unauthorised activity; 300+ warning-list entries. Added to Strategic Signals and the Regulatory Timeline. Sources: FINMA — Annual media conference 2026; SWI swissinfo.ch (21 April 2026).
• Joint CHF stablecoin sandbox (8 April 2026): UBS, PostFinance, Sygnum, Raiffeisen, ZKB, BCV + Swiss Stablecoin AG; sub-CHF 1M sandbox-exempt pilot running through 2026. Added to Strategic Signals and the Regulatory Timeline. Sources (consortium primary releases): UBS (8 April 2026); Sygnum (8 April 2026).
• Circle FinIA consultation response (6 February 2026): USDC/EURC issuer recommended an equivalence-based pathway recognising prudentially regulated third-country stablecoin regimes (citing EU MiCA and the US GENIUS Act). Added to the Regulatory Timeline. Source: Circle (6 February 2026).

Items NOT independently re-verified against primary regulator pages this cycle (reconciled against refreshed source-domain files, which the task designates authoritative): default-guarantee fee ranges and all setup/ongoing CHF cost bands (self-reported/estimated practitioner figures); exact DLT trading facility application processing time (FINMA states it depends on complexity).

Targeted gap-closure pass (2026-06-06):

• Gap [closeable_status] — proposed Payment/Crypto Institution capital thresholds. Investigated whether specific CHF minimum-capital figures have been published. They have NOT. The draft FinIA (FINIG) bill text and two independent law-firm analyses establish that minimum-capital amounts are deliberately delegated to a future implementing ordinance, not fixed in the draft law: Crypto Institution requirements are "modelled on the existing licensing requirements for securities firms" but at ordinance level "tailored specifically to crypto-assets and proportionately reduced in scope"; the Payment Institution removes the FinTech CHF 100M deposit cap and substitutes client-fund segregation plus "stricter capital, liquidity and resolution rules," again with no fixed CHF figure. Refined the TBD wording in Section 3 and the Section 7 "CHF 5 billion deposit cap" signal to state this explicitly rather than a bare "TBD". The gap stays OPEN per the verification standard — no published threshold exists to fetch (the file's honest TBD is correct and now more precise). Sources fetched: Grant Thornton — FinIA amendments / two new licence categories; VELAW — Crypto Institution Licence under FINIG. The draft FINIG bill PDF (law.ch mirror) was fetched but returned compressed/illegible text; its ordinance-delegation structure is corroborated by the two analyses above.

• Gap [closeable_primary_upgrade] — re-fetch FINMA media-conference and sandbox primaries. Independently re-fetched the primary pages previously carried from source-domain files, upgrading them from source-domain reliance to direct fetch this run:

  • FINMA Annual Media Conference 2026 (21 April 2026) — re-fetched directly. CONFIRMED: FINMA "licensed Switzerland's first DLT trading facility in the year under review" (2025); the crypto section is framed around protecting clients "in relation to the purchase, trading and transfer of cryptocurrencies"; 2025 enforcement statistics of 55 concluded proceedings, ~450 investigations into potentially unauthorised activity, and 300+ warning-list entries (a record high). Note: this media-release page states FINMA licensed the first DLT trading facility but does not itself name BX Digital or its trading participants — those specifics trace to the 18 March 2025 FINMA DLT-licence release and remain accurately attributed in the file. Source fetched: FINMA — Annual media conference 2026 (21 April 2026).
  • Joint CHF stablecoin sandbox (8 April 2026) — re-fetched the UBS primary release directly. CONFIRMED participants (UBS, PostFinance, Sygnum, Raiffeisen, Zürcher Kantonalbank, BCV, and Swiss Stablecoin AG), the 8 April 2026 date, and that the sandbox is "a controlled live environment" with "clearly defined safeguards such as a limited participant pool and transaction limits" (the release does not itself state a numeric CHF 1M sandbox-exemption threshold; the file's reference to the sub-CHF 1M sandbox exemption reflects the Swiss sandbox regime, not a figure quoted in this release). The Sygnum mirror of the same release returned HTTP 403 this run; the UBS primary suffices. Source fetched: UBS — joint CHF stablecoin sandbox (8 April 2026). Gap CLOSED.