SWITZERLAND Law and Practice Contributed by: Lukas Morscher and Lukas Staub, Lenz & Staehelin
1. Fintech Market 1.1 Evolution of the Fintech Market
ecosystem, including both emerging and established companies. The total number of fintech-related busi - nesses is much higher. These companies primarily focus on the financial market sector, notably: • payment services; • investment management;
Market conditions for fintech offerings in Switzerland are generally considered favourable. This is due to: • broad access to credit and venture capital; • an educated workforce (a high number of gradu - ates in science and technology); and • widespread access to and use of information and communication technology. Switzerland’s fintech market has experienced sig - nificant growth and expansion for many years, but growth has recently moderated. According to the Swiss Venture Capital Report 2025, total investment in the fintech industry decreased substantially to CHF206 million, in essence a reduction by half, which is the second consecutive decline. While the invest - ment decline is significant, it has to be considered that investments in the fintech sector in the ten years prior grew rapidly, and current numbers are still in the range of pre-pandemic numbers. Swiss legislation was early in focusing on adapting the legal and regulatory framework to the needs of the fintech sector (see 2.4 Variations Between the Regu- lation of Fintech and Legacy Players ), contributing to the dynamic Swiss fintech sector. For example, spe - cific legislation in the area of blockchain came into force in the course of 2021, which made Switzerland an attractive place for fintech start-ups early on (see 10.2 Local Regulators’ Approach to Blockchain ). As activity in the fintech sector has recently moder - ated, the Swiss government is currently seeking to reinvigorate growth with new legislative amendments to future-proof Switzerland’s attractiveness for the fintech sector.
• banking infrastructure; • deposits and lending; • distributed ledger technology (DLT); and • analytics.
Many of these businesses offer their products and services to established financial institutions and/or collaborate on digitisation projects. Switzerland’s fin - tech market is primarily composed of start-ups that receive most of their funding through venture capital. In Switzerland, it is common for established finan - cial service providers to work with emerging fintech companies. The value chain of established financial service providers is being scrutinised and challenged both internally and externally. Emerging fintech companies are developing new technology-driven products and services that have the potential to disrupt the value chain of established players. Established financial service providers gen - erally have the necessary financial and organisational resources to gradually adapt their business process - es, both to avoid this displacement and achieve high market visibility. Conversely, a relatively small number of emerging companies can rely on a trusted brand or a financial market licence (eg, a bank). Back in 2019, the Swiss Financial Market Supervi - sory Authority (FINMA) granted banking licences to fintech players for the first time, namely AMINA Bank AG (formerly Seba AG) and Sygnum, which specialise in assets based on DLT. Other notable fintech play - ers have since received FINMA licences for nearly all types of traditional licences – eg, Revolut Bank UAB (Swiss authorised representative of a foreign bank), Taurus SA (securities firm), VIAC Invest AG (fund manager), Alphemy Capital SA (manager of collective assets) and SDX Trading AG (stock exchange).
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
The Swiss fintech landscape has evolved significantly in recent years, and Switzerland remains an attractive location for financial sector innovators. There are cur - rently over 500 active players in Switzerland’s fintech
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