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FINMA Supervisory Organisations: What Portfolio Managers Need to Know

Published: 5 November 2026 Updated: 7 November 2026 Reading time: 4 min

Supervisory organisations (SOs) carry out the ongoing supervision of FINMA-licensed portfolio managers and trustees in Switzerland; they are themselves authorised and supervised by FINMA (Art. 43a FINMASA). FINMA's list currently shows four SOs: AOOS, OSIF, OSFINcontrol and SO-FIT. Portfolio managers choose their SO before filing the licence application, and according to FINMA a change of SO takes effect at the end of a year.

FINMA supervisory organisations: what portfolio managers need to know – illustrative image (AI)
Reto Picenoni, Board Member, Co-Founder at Peak Compliance
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Board Member, Co-Founder · LinkedIn profile

What it is about

Since the Financial Institutions Act entered into force on 1 January 2020, independent portfolio managers and trustees in Switzerland need a FINMA licence – yet the day-to-day supervision lies elsewhere. It is carried out by supervisory organisations (SOs). For a portfolio manager, the SO is the counterpart for audits, notifications and supervisory questions. This article explains the role of the SOs, what they review and how to choose and, if needed, change your SO.

What a supervisory organisation does

The legal basis is in Title 3 of the Financial Market Supervision Act (FINMASA) and in FinIA:

  • Ongoing supervision: SOs carry out the ongoing supervision of portfolio managers and trustees (Art. 43a para. 1 FINMASA; Art. 61 para. 2 FinIA).
  • Scope of review: the SO verifies whether its supervised firms meet the requirements of FinIA, observe their duties under the AMLA and, where they provide financial services, under FinSA (Art. 84 para. 1 FinIO).
  • Follow-up of findings: if the SO detects breaches, it gives the firm an appropriate period to restore compliance; if the period is not met, it informs FINMA (Art. 43b para. 2 FINMASA).
  • Rulings: decisions in the form of rulings are reserved to FINMA (Art. 84 para. 5 FinIO).
  • Funding: SOs finance their activity through contributions from the firms they supervise (Art. 43f FINMASA).

The SOs themselves need FINMA authorisation, are effectively managed from Switzerland and are supervised by FINMA (Arts. 43a, 43c and 43d FINMASA). FINMA provides them with guidelines for auditing and supervision, including a system of risk assessment (Art. 84 para. 2 FinIO). The supervisory standard is therefore the same, whichever SO you choose.

The supervisory organisations authorised by FINMA

FINMA publishes the list of authorised SOs. As at 5 November 2026 it shows four:

Supervisory organisationRegistered office
AOOS – Schweizerische Aktiengesellschaft für AufsichtZurich
OSIF – Organisme de Surveillance des Instituts FinanciersGeneva
OSFINcontrol AGZug
SO-FIT – Organisme de Surveillance pour Intermédiaires Financiers & TrusteesGeneva

OSFINcontrol was created from the merger of FINcontrol Suisse and OSFIN, which FINMA approved in November 2025; our article on the OSFINcontrol merger has the background.

Audits and reporting

  • Audit firm: the portfolio manager appoints an audit firm in accordance with Art. 43k FINMASA for the annual audit, unless the SO carries out the audit itself (Art. 62 para. 1 FinIA).
  • Audit cycle: the SO may extend the cycle to a maximum of four years, taking account of activity and risks (Art. 62 para. 2 FinIA).
  • Years without an audit: the firm submits a report on its compliance with the law to the SO, which may be in a standardised format (Art. 62 para. 3 FinIA).
  • Changes: changes to the facts on which the licence is based are notified to the SO, which forwards them periodically to FINMA (Art. 22 FinIO).
  • Duty to report: significant incidents are reported to the SO immediately (Art. 43l para. 2 FINMASA).

The current review priorities of the SOs, in particular on FinSA rules of conduct, are summarised in our article on the 2026 supervisory review.

Step by step: choosing your supervisory organisation

  1. 1
    Clarify your profile
    business model, client base, size and the language you want to work in with the SO.
  2. 2
    Compare the SOs
    affiliation agreement, supervision concept, fee structure, communication channels and audit firms used.
  3. 3
    Make contact
    discuss your project with the preferred SO before filing; FINMA's licensing process requires you to choose and contact an SO first.
  4. 4
    Send the application
    submit your licence application with enclosures to the SO via FINMA's survey and application platform (EHP).
  5. ✓
    Receive confirmation
    the SO confirms your affiliation in writing; with this confirmation you file the application with FINMA (Art. 7 para. 2 FinIA).

The whole licensing path is described in our article on how to become a licensed portfolio manager.

Changing your supervisory organisation

According to FINMA, portfolio managers and trustees change their SO at the end of the year, and the licence change request reaches FINMA by 15 November. Plan a change early: talk to the current and the new SO, check notice periods in the affiliation agreements and prepare the documents the new SO requests.

Checklist

  • SO chosen and affiliation agreement reviewed
  • Audit firm appointed or audit by the SO agreed
  • Audit cycle and reporting dates in the compliance calendar
  • Process for notifying changes to the SO defined
  • Annual report on compliance prepared for years without an audit
  • Contact person for SO enquiries named, with a deputy
  • For a change of SO: request timetable aligned with FINMA's 15 November deadline

How Peak Compliance supports you

Peak Compliance works with the supervisory organisations AOOS and OSFINcontrol, prepares audits and notifications and represents your compliance function in the dialogue with your SO. For new firms, we guide the portfolio manager licence including the choice of SO; background is in our FinIA knowledge hub. For a first conversation, reach us via the contact page.

Frequently asked questions

What does a FINMA supervisory organisation do for portfolio managers?

A supervisory organisation (SO) carries out the ongoing supervision of FINMA-licensed portfolio managers and trustees (Art. 43a para. 1 FINMASA). It verifies whether its supervised firms meet the requirements of FinIA and observe their duties under the AMLA and, where they provide financial services, under FinSA. The SOs are themselves authorised and supervised by FINMA; as at 5 November 2026, FINMA’s list shows four: AOOS, OSIF, OSFINcontrol and SO-FIT.

How often is a portfolio manager audited?

A portfolio manager is audited as a rule annually, by an audit firm appointed in accordance with Art. 43k FINMASA or by the supervisory organisation itself. The supervisory organisation may extend the audit cycle to a maximum of four years, depending on activity and risks; in the years in between, the firm submits a report on its compliance with the law to the supervisory organisation (Art. 62 FinIA).

When can a portfolio manager change its supervisory organisation?

According to FINMA, a portfolio manager changes its supervisory organisation at the end of the year, and the corresponding licence change request reaches FINMA by 15 November. Plan the change early: talk to both the current and the new supervisory organisation, check the notice periods in the affiliation agreements and prepare the documents the new supervisory organisation requests.

Sources

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