Swiss Stablecoin Regulation — FINMA Guidance 06/2024 & Federal Council Proposals

Swiss Stablecoin Regulation

FINMA Guidance 06/2024, published in mid-2024, clarified the regulatory treatment of stablecoins in Switzerland with significant implications for issuers, custodians, and platforms trading CHF-denominated stable tokens. The guidance established that fiat-referenced stablecoins are treated as deposits under the Banking Act, meaning issuers require either a banking license or a bank guarantee to operate legally. Combined with the Federal Council’s October 2025 proposal for dedicated payment institution licenses with exclusive stablecoin issuance rights, the Swiss stablecoin regulatory landscape is undergoing fundamental restructuring.

FINMA Guidance 06/2024 — Core Provisions

The guidance addresses the classification of stablecoins pegged to fiat currencies (CHF, USD, EUR). FINMA’s analysis is straightforward: when an issuer accepts funds from the public in exchange for tokens that represent a claim to repayment in fiat currency, the issuer is accepting public deposits. Under the Swiss Banking Act, accepting public deposits requires a banking license unless a specific exemption applies.

This classification has several operational consequences. First, stablecoin issuers without banking licenses must either obtain a banking license or secure a bank guarantee from a licensed Swiss bank. The bank guarantee must ensure that all outstanding stablecoin obligations can be met if the issuer becomes insolvent. Second, individual customer claims against the issuing bank must survive the stablecoin issuer’s bankruptcy — meaning the bank guarantee creates direct claims for each stablecoin holder, not merely a claim by the issuer against the guarantor bank.

Third, the guidance addresses reserve management. Reserves backing fiat-referenced stablecoins must be held in liquid, low-risk assets — primarily bank deposits and short-term government securities. The reserve composition must ensure that the stablecoin can be redeemed at par value at all times. This requirement effectively prohibits algorithmic stablecoins (which maintain peg through token supply management rather than fiat reserves) from operating as regulated stablecoins in Switzerland.

Impact on Current Stablecoin Projects

Sygnum Bank’s DCHF stablecoin is fully compliant with Guidance 06/2024. As a FINMA-licensed bank, Sygnum can accept deposits and issue stablecoins directly. Moreover, DCHF is backed by SNB sight deposits — the highest-quality reserve asset possible — providing maximum redemption certainty.

The defunct CryptoFranc (XCHF) by Bitcoin Suisse operated under a bank guarantee model. Its August 2024 discontinuation, while driven by insufficient market adoption rather than regulatory pressure, illustrates the challenges of operating a stablecoin outside the banking license framework — the bank guarantee arrangement adds cost and complexity that erodes economic viability for low-volume stablecoins.

AllUnity’s CHFAU, launched in February 2026 as the first fully MiCAR-compliant CHF stablecoin, represents a cross-jurisdictional compliance approach — satisfying both EU MiCA requirements and positioning for Swiss regulatory alignment as the new payment institution license framework takes effect.

Frankencoin (ZCHF), a decentralized CHF stablecoin operating from Zug, presents a regulatory frontier. As a decentralized protocol without a centralized issuer, Frankencoin does not fit neatly into the deposit-taking framework of Guidance 06/2024. FINMA has not yet issued specific guidance on decentralized stablecoins, but the principle-based approach suggests that if no entity accepts deposits or issues tokens with redemption claims, the Banking Act deposit framework may not apply. This regulatory grey area is being closely monitored by the Swiss blockchain community.

Federal Council Payment Institution Proposal

The October 2025 Federal Council proposal would create a dedicated payment institution license with exclusive authority to issue Regulated Stablecoins. This builds on Guidance 06/2024 by moving from guidance-level clarification to statutory-level regulation. The proposed framework would codify the reserve requirements, redemption obligations, and customer protection provisions currently addressed through FINMA guidance into federal law.

The payment institution license removes the CHF 100 million deposit cap of the current fintech license, allowing stablecoin issuers to scale operations without converting to a full banking license. This creates a proportionate regulatory pathway — less burdensome than a banking license but more stringent than SRO membership — calibrated for the specific risk profile of stablecoin issuance.

AML Obligations for Stablecoin Issuers

FINMA Guidance 06/2024 placed particular emphasis on the AML risks associated with stablecoins. Because stablecoins are intended as payment instruments — enabling value transfer between parties — they present elevated risks for money laundering, terrorist financing, and sanctions circumvention compared to volatile cryptocurrencies that are less practical as payment media. FINMA classifies stablecoin issuers as financial intermediaries under the Anti-Money Laundering Act (AMLA), subjecting them to comprehensive AML obligations.

The “know-your-holder” obligation requires stablecoin issuers to identify all token holders — not merely the initial purchasers but subsequent acquirers through secondary market trading. This obligation necessitates technical and contractual transmission restrictions that prevent anonymous holding. Issuers must implement systems to track token ownership changes and verify the identity of new holders when tokens are transferred. In practice, this means that fully permissionless stablecoins — where any wallet can hold the token without identification — face significant regulatory challenges in Switzerland.

The Travel Rule applies to stablecoin transfers with a threshold of CHF 0 — meaning all blockchain transactions involving stablecoins, regardless of amount, require originator and beneficiary information transmission. This zero-threshold application reflects FINMA’s assessment that stablecoins, as payment instruments, warrant the same AML scrutiny as traditional fiat payment channels.

The Swiss Bankers Association Position

The Swiss Bankers Association (SBA) published a significant report on stablecoins in April 2025. SBA Chief Economist Martin Hess identified stablecoins as efficient, innovative, low-cost, and secure payment instruments with potential to streamline cross-border transactions, support digital asset trading, and enable future DeFi services. However, the report also highlighted systemic risks: large-scale stablecoin issuance could undermine banks’ intermediary role because every stablecoin held instead of a bank deposit reduces a bank’s loan refinancing capacity.

The SBA’s position creates direct tension with the Federal Council’s proposed regulatory framework. The 2025 proposal requires banks that wish to issue Regulated Stablecoins to establish separate legal entities — preventing banks from issuing stablecoins directly on their balance sheets. The SBA challenges this requirement, demanding direct stablecoin issuance rights for banks. The argument centers on competitive fairness: if banks cannot issue stablecoins directly while non-bank payment institutions can, banks face a structural disadvantage in the emerging digital payments landscape.

This institutional debate will shape the final legislative text. The consultation period closed in February 2026, and parliamentary deliberation is expected in 2026-2027. The outcome will determine whether Swiss banks join specialized payment institutions as stablecoin issuers or remain restricted to supporting non-bank issuers through banking services and guarantees.

CHF Stablecoin Market Context

The CHF stablecoin market remains a niche within the global stablecoin landscape. At approximately $40 million in total market capitalization, CHF-denominated stablecoins represent just 0.13% of the global stablecoin market, which processes $33 trillion in annual transaction volume (a 72% increase year-over-year). The dominant global stablecoins — USDT (Tether), USDC (Circle), and DAI (MakerDAO) — are all USD-denominated, reflecting the US dollar’s role as the primary currency for crypto trading pairs and DeFi protocols.

The small size of the CHF stablecoin market presents both a challenge and an opportunity. The challenge: limited market adoption of CHF stablecoins may not justify the regulatory compliance costs for issuers, as demonstrated by the discontinuation of CryptoFranc (XCHF) by Bitcoin Suisse in August 2024 due to insufficient market adoption. The opportunity: as Project Helvetia establishes wholesale CBDC settlement on SDX and tokenized bond issuance grows (CHF 750+ million and counting), the demand for CHF-denominated digital payment instruments may increase alongside institutional tokenization activity.

The emerging CHF stablecoin issuers reflect this institutional dynamic. Sygnum Bank’s DCHF stablecoin targets institutional clients and is backed by SNB sight deposits — the highest-quality reserve asset possible. AllUnity’s CHFAU, launched in February 2026 as the first MiCAR-compliant CHF stablecoin, is available exclusively for institutional and professional clients. Frankencoin (ZCHF), the decentralized alternative operating from Zug, has spawned derivative products through Plusplus, a Zug-based fintech. Swiss Stablecoin, founded by former National Council member Pascale Bruderer, is developing CHFD with a focus on simplifying the Swiss payment system.

Comparison with EU MiCA Stablecoin Framework

The EU’s Markets in Crypto-Assets Regulation (MiCA), fully applicable since December 2024, provides a comprehensive stablecoin framework that contrasts with Switzerland’s evolving approach. MiCA creates two specific token categories: Asset-Referenced Tokens (ARTs) and E-Money Tokens (EMTs). ARTs maintain value by referencing multiple assets (basket stablecoins), while EMTs reference a single fiat currency (standard stablecoins like USDT or USDC).

MiCA requires stablecoin issuers to obtain authorization from EU national competent authorities, publish and maintain detailed white papers, hold reserves in custody at authorized credit institutions, and submit to regulatory reporting requirements. The framework is comprehensive and prescriptive — in contrast with Switzerland’s current reliance on guidance-level clarification (FINMA Guidance 06/2024) pending legislative enactment of the 2025 proposals.

Swiss companies issuing stablecoins for EU customers must comply with MiCA regardless of their Swiss regulatory status. AMINA Bank obtained a MiCA license from the Austrian FMA in November 2025 — the first bank globally with a MiCA license — enabling regulated crypto services across the EU. AllUnity’s CHFAU stablecoin is positioned as MiCAR-compliant from launch. For Swiss-domiciled stablecoin issuers, dual compliance (Swiss regulations and EU MiCA) is the operational reality. Our Switzerland vs EU MiCA comparison analyzes these regulatory divergences in detail.

Algorithmic Stablecoins and Regulatory Treatment

FINMA’s reserve requirements under Guidance 06/2024 effectively prohibit algorithmic stablecoins from operating as Regulated Stablecoins in Switzerland. Algorithmic stablecoins maintain their peg through token supply management — minting and burning tokens based on market demand — rather than holding fiat reserves. Because FINMA requires reserves backing fiat-referenced stablecoins to be held in liquid, low-risk assets (primarily bank deposits and short-term government securities), an algorithmic stablecoin without fiat reserves cannot satisfy the guidance requirements.

The Federal Council’s 2025 proposal codifies this position by defining a Regulated Stablecoin as a crypto asset that confers a redemption claim to the holder against the issuer — requiring both fiat reserves and a legal claim to redemption. Algorithmic stablecoins, which typically do not provide a legal claim to redemption in fiat currency, fall outside this definition. The collapse of Terra/LUNA in 2022 — which erased approximately $40 billion in market value — reinforced regulators’ skepticism toward algorithmic stability mechanisms and validated FINMA’s reserve-based approach.

Cross-Border Stablecoin Compliance

Swiss stablecoin issuers serving international markets face multi-jurisdictional compliance requirements. For EU customers, MiCA compliance is mandatory since December 2024. AMINA Bank obtained a MiCA license from the Austrian FMA in November 2025, enabling EU-wide stablecoin services. For US customers, the GENIUS Act (signed July 2025) establishes additional requirements. Swiss issuers must evaluate each target market’s regulatory framework and maintain compliance with all applicable jurisdictions simultaneously. The proposed Swiss payment institution license would provide the domestic regulatory foundation, but international distribution requires supplementary authorizations in each target jurisdiction. This multi-regulatory reality increases compliance costs but creates a competitive moat for issuers that achieve comprehensive authorization — their stablecoins can serve global institutional clients with regulatory certainty that unlicensed competitors cannot match. The ongoing evolution of global stablecoin regulation — with the EU, US, UK, Singapore, and Japan all implementing or proposing stablecoin-specific frameworks — means that Swiss issuers must continuously monitor and adapt to regulatory changes in their target markets while maintaining domestic compliance with FINMA’s evolving guidance and the proposed payment institution license framework.

Stablecoin Market Development and Institutional Adoption

The global stablecoin market has grown significantly, with total market capitalization exceeding $200 billion as of early 2026. Switzerland’s regulated stablecoin ecosystem, while representing a small fraction of this global market in absolute terms, provides the institutional-grade compliance infrastructure that distinguishes Swiss stablecoin offerings from unregulated alternatives. Sygnum Bank’s DCHF, backed by Swiss National Bank sight deposits, represents the gold standard for institutional CHF stablecoin design, providing on-chain CHF liquidity with central bank collateral quality that no competing CHF stablecoin can match. The Frankencoin (ZCHF) decentralized approach provides an alternative model that operates outside the regulated stablecoin framework, using over-collateralization rather than fiat reserves to maintain its peg. As the Federal Council’s proposed payment institution framework takes shape, the Swiss stablecoin landscape will likely bifurcate between fully regulated institutional stablecoins (DCHF, CHFAU) and decentralized alternatives (ZCHF) that operate outside the formal regulatory perimeter.

For detailed analysis of the payment institution license proposal, see our dedicated coverage. For the broader FINMA token classification framework, see our classification analysis. For stablecoin project profiles, visit our Swiss stablecoin landscape analysis. For how stablecoin regulation intersects with Project Helvetia wholesale CBDC, explore our central bank coverage. For Crypto Valley entity profiles of stablecoin issuers and custodians, browse our ecosystem section. For DAO governance implications of stablecoin treasury management, see our governance analysis. For AML/KYC obligations specific to stablecoin issuers, see our compliance coverage. For external reference, consult FINMA’s stablecoin guidance.