What it is about
The Swiss client adviser register makes sure that advisers who serve clients in Switzerland know the rules of conduct of the Financial Services Act (FinSA). It matters above all for client advisers of foreign banks, wealth managers and brokers who travel to Switzerland or serve Swiss clients remotely, and for Swiss providers that are not prudentially supervised. This article explains who must register, who is exempt and how registration works in practice.
Who must register
The starting point is Art. 28 para. 1 FinSA: client advisers of Swiss financial service providers that are not supervised under Art. 3 FINMASA, and client advisers of foreign financial service providers, may work in Switzerland only once they are entered in a register of advisers.
| Situation | Registration |
|---|---|
| Foreign provider, not prudentially supervised in its home country | required |
| Foreign provider, prudentially supervised abroad, serving retail clients in Switzerland | required |
| Foreign provider, prudentially supervised abroad, serving exclusively professional or institutional clients in Switzerland | exempt (Art. 31 FinSO) |
| Swiss provider without prudential supervision | required |
| Swiss representative office of a foreign bank or financial institution serving retail clients in Switzerland | required, according to FINMA since 1 August 2021 |
The exemption depends on the segment of every client served in Switzerland. According to FINMA, high-net-worth retail clients who have opted to be treated as professional clients still count as retail clients for this test, so a single opted-out private client is enough to trigger the duty to register. Our article on FinSA client segmentation explains the segments in detail.
What registration requires
Client advisers are entered in the register if they prove three things (Art. 29 para. 1 FinSA):
- Knowledge: sufficient knowledge of the FinSA rules of conduct and the expertise needed for their activity (Art. 6 FinSA).
- Insurance: professional indemnity insurance or equivalent collateral. The minimum cover is CHF 500'000 per year for one adviser and rises with the number of insured advisers (Art. 32 FinSO); where advisers are employed by a provider, the provider can take out the insurance (Art. 29 para. 3 FinSA).
- Ombudsman's office: affiliation with an ombudsman's office, by the adviser or the provider, where a duty to affiliate exists.
Persons convicted of certain offences under FinSA or the Insurance Supervision Act or of property offences under the Swiss Criminal Code, or subject to an activity or professional ban, are not entered (Art. 29 para. 2 FinSA).
The register shows, among other things, the adviser's name, the financial service provider, function, fields of activity, completed training and the ombudsman's office (Art. 30 FinSA).
Who keeps the register
Registration bodies keep the register; they need a licence from FINMA (Art. 31 FinSA). FINMA's list, updated on 5 November 2026, shows three licensed registration bodies, among them BX Swiss AG and RegFix. Each registration body keeps its own register, decides on entries and deletions and sets its own application procedure. You choose the registration body that suits you.
Step by step to the register
- 1Check the dutyclarify the regulatory status of your firm and the segments of the clients you serve in Switzerland.
- 2Prove knowledgecomplete a FinSA training on the rules of conduct that the registration body accepts and keep the certificate.
- 3Arrange insurancetake out professional indemnity insurance or provide equivalent collateral.
- 4Confirm the ombudsman's officedocument the affiliation of the adviser or the provider.
- 5Applysubmit the application with all evidence to the registration body of your choice.
- ✓Keep the entry up to datereport changes within 14 days and renew the entry after 24 months at the latest (Art. 41 FinSO).
Checklist
- Regulatory status of the provider and client segments in Switzerland clarified
- Exemption under Art. 31 FinSO checked and documented, where relevant
- Training certificate on the FinSA rules of conduct available
- Professional indemnity insurance with sufficient cover in place
- Ombudsman's office confirmed
- Registration body chosen and application submitted
- Process for reporting changes within 14 days defined
- Renewal date in the calendar, with a refresher planned in time
How Peak Compliance supports you
Peak Compliance offers the Swiss client adviser register training online in English and German: the basic training for the first entry and the refresher for the renewal, both on the list of training providers of BX Swiss AG and listed by RegFix. The legal framework is summarised in our FinSA knowledge hub. For questions about your situation, reach us via the contact page.
