🇨🇭 Switzerland vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Switzerland and United Kingdom are commonly considered side by side for e-money authorisation. In Switzerland the route is the No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence. overseen by FINMA.; in United Kingdom it is the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. under Financial Conduct Authority (FCA).. The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Switzerland: verified 2026-10-01 · United Kingdom: verified 2026-10-01
| Dimension |
🇨🇭 Switzerland
analogue
partly open
Verified 2026-10-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
|
|---|---|---|
| Licence type | No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | FINMA. | Financial Conduct Authority (FCA). |
| Capital requirement | Switzerland capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Switzerland timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Switzerland local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Switzerland application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | Switzerland ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Switzerland passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Switzerland emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Switzerland key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Switzerland safeguarding is included in the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| Recent changes | The Federal Council launched consultation on 22 October 2025 on Financial Institutions Act amendments that would replace the FinTech licence with payment instrument institution and crypto-institution categories. The consultation closed on 6 February 2026. The proposal would remove the CHF 100 million client-deposit cap and allow payment instrument institutions to issue specified stablecoins. The current FINMA FinTech licence and its CHF 100 million cap remain in force pending legislation. | HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins. |
| Difficulty rating | Switzerland difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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What changed recently
🇨🇭 Switzerland (verified 2026-10-01): The Federal Council launched consultation on 22 October 2025 on Financial Institutions Act amendments that would replace the FinTech licence with payment instrument institution and crypto-institution categories. The consultation closed on 6 February 2026. The proposal would remove the CHF 100 million client-deposit cap and allow payment instrument institutions to issue specified stablecoins. The current FINMA FinTech licence and its CHF 100 million cap remain in force pending legislation.
🇬🇧 United Kingdom (verified 2026-10-01): HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins.
Quick answers
Who regulates e-money licensing in Switzerland and United Kingdom?
Switzerland: FINMA.. United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Switzerland compared with United Kingdom?
In Switzerland the authorisation route is No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence.; in United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Switzerland vs United Kingdom comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/switzerland-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.