The page was expanded to include detailed licensing and authorisation criteria for FinTech companies, DLT trading facilities, and operations involving cryptobased assets and blockchain.
Before
The page provided only high-level summaries of anti-money laundering and general authorisation requirements for FinTech without specific licensing thresholds for DLT trading or individual blockchain custody.
After
The page specifies that a FinTech licence is required to accept client deposits up to CHF 100 million or take collective custody of cryptobased assets, and outlines specific conditions where holding cryptobased assets on individual blockchain addresses is exempt from a banking licence.
Source: Switzerland FINMA — DLT Act & Token Classification
View original source →What this means for you
Centralized Exchange
Review soonWhy this matters
The new regulatory guidance explicitly details FinTech licence requirements and conditions for accepting client deposits and taking collective custody of crypto-based assets up to CHF 100 million. As a centralized exchange that custodies user funds and operates a trading platform, the company must evaluate whether its current authorization aligns with these specific thresholds and exemption criteria.
What to do
Review current licensing status and custody thresholds against the new FinTech licence criteria and crypto-holding exemptions to ensure proper authorization.
DeFi Protocol
Doesn't applyWhy this matters
The regulatory change imposes licensing requirements for accepting client deposits and taking collective custody of crypto-based assets. Because the profile is a fully decentralized protocol with no operator, owner, or entity that custodies user assets, there is no legal person for these licensing obligations to attach to.
Custodian
Review soonWhy this matters
The new regulatory guidance directly impacts the company's core business of holding crypto-assets on behalf of clients by detailing specific FinTech and banking licence thresholds and exemptions for collective custody and individual blockchain addresses. Because this profile operates as a custodian responsible for client assets, it must evaluate whether its current licensing status covers these updated thresholds and exemptions to avoid operating without the proper authorization.
What to do
Review current custody asset volumes and wallet architecture against the new CHF 100 million deposit threshold and individual address exemption criteria to confirm proper licensing coverage.