SWITZERLAND Trends and Developments Contributed by: Kilian Schärli, Reto Luthiger, Andrea Trost and Diana Lafita, MLL Legal
have sufficient potential to push the sector forward. In November 2025, Swiss banks launched retail multi - banking via the bLink platform operated by SIX, which the bank customers of eight Swiss banks and two third-party service providers can use to bundle their accounts from various banks into one banking or fin - tech app – with more than 30 banks offering the nec - essary data interface. In 2023, the SBA established an open banking framework in a memorandum of under - standing (MOU) to facilitate open banking amongst different stakeholders. Crypto services: use of distributed ledger technology to register ownership and conduct transactions and trading Payment tokens (cryptocurrencies) are tokens intend - ed to be used as a means of payment without giving rise to any claim against an issuer. The custody of payment tokens can, however, trigger the application of the banking or fintech licence regulations. Sygnum Bank and AMINA Bank are well-known banks in the fintech space that offer storage of cryptocurrencies. Besides banks, Switzerland has several pure-play wallet providers, such as Relai, Swiss Fortress and Thor Wallet. These providers hold cryptocurrencies in either individual custodial or non-custodial wal - lets (both bankruptcy-remote). This is the reason why they do not require a banking licence, but in case of custodial wallets may be subject to AML regulations. In contrast, so-called asset tokens that represent a claim against an issuer (such as a debt or equity claim) qualify as securities if they are standardised and mass-tradable. To date, banks and licensed securities brokers or dealers have yet to achieve significant success in issuing stablecoins. Stablecoins have the potential to disrupt payment systems and traditional business models, and can potentially pose a challenge to mon - etary policy, as they can be seen as a substitute for fiat currencies. The SNB has stated that there is no need for digital central bank money for the public, as the Swiss payment system is already offering instant payment capabilities with the SIC system. The SNB has conducted pilot projects involving central bank digital currencies (CBDCs) by expanding Project Hel - vetia in mid-2025 to settle tokenised assets in central bank money.
In September 2025, an e-ID system was approved by the introduction of the e-ID Act, enabling digital identity with privacy protection issued by the state on request of the data owner. This development is expected to accelerate the adoption of embedded finance solutions, enabling efficient and selective dis - closure and KYC. In Switzerland, the licensing category of “DLT trad - ing venue” enables the multilateral trading of ledger- based securities on the blockchain on the basis of non-discretionary rules and may encompass, in addi - tion to trading: • direct access to retail; • the holding of ledger-based securities in central custody; and • clearing and settlement. BX Digital remains the only DLT trading platform in Switzerland at present. It announced in 2025 that it will admit tokenised stocks of Ondo Global Markets to trading. In large part, investments in crypto-assets are made into cryptocurrencies, such as Bitcoin or Ether, which are offered by private and cantonal banks. Since 2013, Bitcoin Suisse has offered investments in crypto- assets, providing storage in individual vaults or col - lective wallets. Collective custody of cryptocurrencies usually requires a banking or fintech licence, unless there is a default guarantee from a bank or another exemption applies. 21 Shares offers a large amount of cryptocurrency exchange-traded products (ETPs) listed on regulated exchanges. Structural impact of industry trends Fractionalisation and tokenisation The tokenisation and fractional ownership of secu - rities, when paired with AI, enables the creation of investment strategies tailored to individual clients, potentially rendering traditional collective investment scheme structures unnecessary. By holding fractional - ised financial instruments directly in an investor’s wal - let, AI can facilitate the management of these secu - rities entirely within the wallet, eliminating the need for any third-party fund. Some banks, such as Pictet Asset Management, have been testing this model
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