What it is about
Independent asset managers, wealth managers and external asset managers (EAMs) in Switzerland all fall under the same licence: the FINMA licence as a portfolio manager under Art. 17 of the Financial Institutions Act (FinIA). This article is for founders and teams who want to understand the path before they start – which questions to answer first, what FINMA expects and how to sequence the work. The detailed service description and the timeline are on our page FINMA licence for portfolio managers.
Do you need a portfolio manager licence?
A portfolio manager is a person who manages assets on a commercial basis in the name and on behalf of clients (Art. 17 para. 1 FinIA). Three questions settle which licence fits:
- Do you manage client assets with discretionary authority? Then you are a portfolio manager and need a FINMA licence before starting operations (Art. 5 FinIA).
- Do you manage collective investment schemes or pension fund assets? Then the licence as a manager of collective assets under Art. 24 FinIA may apply. Below certain thresholds – for example collective assets of up to CHF 100 million, including leverage, for qualified investors – such managers count as portfolio managers (Art. 24 para. 2 FinIA).
- Do you act as a trustee? Trustees need their own licence; a portfolio manager who also acts as trustee needs an additional licence (Art. 20 FinIO).
What FINMA requires
| Requirement | What the law says | What to prepare |
|---|---|---|
| Legal form | sole proprietorship, commercial enterprise or cooperative (Art. 18 FinIA) | articles of association, shareholder structure |
| Place of management | effectively managed from Switzerland (Art. 10 FinIA) | residence and availability of the managers |
| Management | at least two qualified persons (Art. 20 FinIA) | CVs, evidence of five years' experience and 40 hours of training (Art. 25 FinIO) |
| Fit and proper | guarantee of irreproachable business conduct (Art. 11 FinIA) | personal documents as requested in the FINMA application form |
| Risk management and internal control | appropriate system, separate from the activities supervised (Art. 21 FinIA) | directives, control plan, risk tolerance (Art. 26 FinIO) |
| Capital | CHF 100'000 minimum capital, paid up in cash; collateral or professional liability insurance (Art. 22 FinIA) | bank confirmation, insurance policy |
| Supervision | proof of supervision by a supervisory organisation (Art. 7 para. 2 FinIA) | confirmation of affiliation |
Risk management and internal control may be performed by a qualified manager, by qualified employees or by a qualified external entity (Art. 21 para. 2 FinIA). Many new firms therefore name an external compliance and risk management function in the application. Our article on the internal control system for portfolio managers, listed below under related articles, shows how such a system works in daily practice.
Step by step to the licence
- 1Business modeldefine services, target clients, client domiciles, custodian banks and expected assets under management; this decides the licence type.
- 2Teamappoint at least two qualified managers and plan deputies; clarify the board and its oversight role.
- 3Organisationdraft the organisational regulations, directives on compliance, anti-money laundering and FinSA rules of conduct, and the business plan.
- 4Supervisory organisationchoose one of the supervisory organisations authorised by FINMA; our article on supervisory organisations explains the criteria.
- 5EHP applicationregister on FINMA's survey and application platform and complete the application form with all enclosures.
- 6Confirmation and filingsend the application to the supervisory organisation via the EHP, receive its written confirmation and file the application with FINMA.
- ✓Licence and startafter FINMA's decision, the firm is entered in the commercial register (Art. 5 para. 2 FinIA) and ongoing supervision by the supervisory organisation begins.
How long does it take?
With Peak Compliance, the path from the needs analysis to the licence typically takes four to six months. The decisive factor is a complete file: questions from the supervisory organisation or FINMA take time, and FINMA decides on the outcome and its timing. The FINMA application form is available in German, French, Italian and English, which helps international founders.
After the licence
The licence is the start of ongoing duties. The supervisory organisation checks compliance with FinIA, AMLA and FinSA (Art. 84 FinIO), and an audit firm generally audits annually; the supervisory organisation may extend the cycle to up to four years (Art. 62 FinIA). Changes to the facts on which the licence is based are notified to the supervisory organisation (Art. 22 FinIO). The current audit priorities are summarised in our article on the 2026 supervisory review; the wider legal framework is in the FinIA knowledge hub.
Checklist
- Business model, target clients and licence type defined
- At least two qualified managers with evidence of experience and training
- Management effectively exercised from Switzerland
- Organisational regulations and directives drafted
- Risk management, internal control and compliance staffed, internally or externally
- CHF 100'000 minimum capital and collateral or professional liability insurance in place
- Supervisory organisation chosen and contacted
- EHP registration completed and application prepared
- Timetable for commercial register entry and start of operations agreed
How Peak Compliance supports you
Peak Compliance prepares the organisation and documents with you, guides the application through the supervisory organisation and FINMA and can take over compliance and risk management from day one. An overview of all licence types is on FINMA and FMA licensing. For a first conversation, reach us via the contact page.
