🇨🇭 Switzerland vs 🇬🇧 United Kingdom: e-money licensing compared
Switzerland and United Kingdom take recognisably different routes to 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 two regimes differ on 7 of 10 tracked decision dimensions, including capital requirement and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
Switzerland: verified 2026-07-03 · United Kingdom: verified 2026-07-03
| Dimension |
🇨🇭 Switzerland
analogue
partly open
Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with 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 locked. Unlock with the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Switzerland local substance is locked. Unlock with the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Switzerland application cost is locked. Unlock with the £349 pass. | FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional. |
| Ongoing cost | Switzerland ongoing cost is locked. Unlock with the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Switzerland passporting is locked. Unlock with the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Switzerland emis authorised is locked. Unlock with 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 locked. Unlock with the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Switzerland safeguarding is locked. Unlock with 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 | Federal Council launched public consultation on 22 October 2025 on FinIA amendments to replace the FinTech licence with two new categories: a payment instrument institution licence (permitting stablecoin issuance, removing the CHF 100m deposit cap) and a crypto-institution licence. Consultation closed 6 February 2026. Entry into force expected in 2027 at the earliest, so the current FinTech licence and its CHF 100m cap remain in effect for now. | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. |
| Difficulty rating | Switzerland difficulty rating is locked. Unlock with the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
The two regimes differ on 7 of 10 tracked decision dimensions, including capital requirement and local substance. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇨🇭 Switzerland (verified 2026-07-03): Federal Council launched public consultation on 22 October 2025 on FinIA amendments to replace the FinTech licence with two new categories: a payment instrument institution licence (permitting stablecoin issuance, removing the CHF 100m deposit cap) and a crypto-institution licence. Consultation closed 6 February 2026. Entry into force expected in 2027 at the earliest, so the current FinTech licence and its CHF 100m cap remain in effect for now.
🇬🇧 United Kingdom (verified 2026-07-03): FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.
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.