SWITZERLAND Law and Practice Contributed by: Oliver Widmer and Niku Gholamalizadeh, Pestalozzi
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain Switzerland’s Crypto Valley remains one of the world’s leading blockchain hubs. According to the CV VC Top 50 Report, the combined valuation of the top 50 block- chain companies in Switzerland and Liechtenstein reached USD461.8 billion in 2025, a 21% increase year-on-year. This is partly associated with increas- ing regulation Switzerland, but also reflects currently prevailing global geopolitical insecurities, which typi- cally slow down investment activity in non-traditional areas. Nevertheless, the outlook for the Crypto Valley remains optimistic as both established companies and start-ups continue to develop and adapt tech- nologies. In particular, the upcoming AI integration leading to transaction cost efficiency is expected to accelerate growth on blockchain markets. As in previous years, Zug continues to retain its lead- ing position as a hub for the industry within the Crypto Valley, while Zurich and Liechtenstein have also seen increased venture funding activities. Common use cases include cryptocurrency exchange platforms, tokenisation platforms, custodial and non-custodial wallet services, hot and cold storage solutions, sup- ply chain and trade finance solutions, and DeFi appli- cations. The SIX Digital Exchange (SDX), the world’s first fully regulated digital asset exchange, is a flag- ship example, offering integrated issuance, trading, settlement and custody for digital assets. A signifi- cant milestone was reached in March 2025, when the Swiss Financial Market Supervisory Authority (FINMA) granted the first-ever digital ledger technology (DLT) trading facility licence to BX Digital AG, enabling regu- lated trading and settlement of DLT securities on the Ethereum blockchain. It was the first licence granted based on Switzerland’s DLT Act, which entered into force in August 2021. The development and use of blockchain in Switzer- land are influenced by a range of regulatory and legal considerations at both international and domestic level. The most significant domestic development is the proposed amendment to the Financial Institutions Act (FinIA), currently progressing through the legisla-
tive process following a consultation that closed in February 2026. This revision aims to improve the regu- latory framework for stablecoins and crypto-assets, enhance Switzerland’s competitiveness as a financial centre, and implement international standards. Fur- thermore, FINMA’s evolving guidance on stablecoins and AML requirements will continue to shape how projects are structured. Externally, MiCA remains a key consideration, since Swiss entities serving EU- based customers must comply with it, despite Swit- zerland not being an EU member. Switzerland’s general technology neutral legal approach means that existing laws apply to block- chain based products and services without specific adaptation. However, the Swiss crypto-specific regu- latory environment is evolving and industry-specific laws and regulations are being introduced to foster legal certainty while maintaining a competitive envi- ronment. 1.1.2 Regulatory Sandbox Under Swiss law, only a single regulatory sandbox exists, which can be used by Swiss blockchain-based businesses qualifying as banks. In order to qualify for this banking sandbox, the blockchain-based business must satisfy the follow- ing requirements: • the acceptance of deposits must not exceed the maximum amount of CHF1 million (even if such deposits are made by more than 20 depositors), provided that such deposits are not invested by the Swiss company and do not bear interest; and • depositors must be informed (in writing) in advance that the Swiss company is not subject to FINMA supervision and that deposits are not covered by the deposit guarantee scheme. If these criteria are fulfilled, the deposit-taking activity will not be deemed to be “on a professional basis”. Despite not being a “sandbox” by definition, it is worth mentioning that Swiss licensing requirements apply, in principle, to activities carried out on a “profes- sional basis”. The criteria of activities being carried out on a professional basis are defined separately for
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