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| Dimension |
Pinned 🇨🇭 Switzerland analogue partly open Verified 2026-08-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
|
|---|---|---|
| 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 | 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 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | Switzerland difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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