FinIA (FINIG) and supervision: licensing, organisation and supervisory organisations

The Swiss Financial Institutions Act (FinIA, in German FINIG) defines which financial institutions need a FINMA licence and what is required in terms of organisation and fit and proper conduct; portfolio managers and trustees are supervised on an ongoing basis by a supervisory organisation. Peak Compliance supports licensing procedures under Art. 17 and Art. 24 FinIA, works with the supervisory organisations AOOS and OSFINcontrol and brings together provisions and articles here.

Responsible: Isabelle Ledergerber Last reviewed: 5 November 2026

Licensing and supervision at a glance

InstitutionProvisionLicenceOngoing supervision
Portfolio manager, trusteeArt. 17 FinIAFINMAsupervisory organisation (Art. 61 FinIA)
Manager of collective assetsArt. 24 FinIAFINMAFINMA

Further core provisions: Art. 2 FinIA (financial institutions), Art. 5 FinIA (licensing requirement), Art. 9 FinIA (organisation). FINMA explains the procedure on its pages on portfolio managers and trustees and on supervisory organisations (in German).

What FinIA means for portfolio managers

  1. 1
    Choose a supervisory organisation
    portfolio managers under Art. 17 FinIA arrange affiliation with a supervisory organisation as the first step; the FINMA application builds on it.
  2. 2
    Build the organisation
    set up executive management, compliance and risk management appropriately – in-house or outsourced.
  3. 3
    Evidence fit and proper conduct
    document the qualifications and good reputation of the persons responsible.
  4. 4
    Secure financial guarantees
    evidence the funds required by law.
  5. ✓
    Comply on an ongoing basis
    meet the licensing conditions at all times, notify changes in advance and present a remediation plan promptly where needed.

How Peak Compliance supports you

Articles on FinIA and supervision

Planning a licence or preparing your organisation for supervision? Talk to us.

At a glance

  • Act: Federal Act on Financial Institutions (FinIA, SR 954.1), with FinIO and FinIO-FINMA.
  • Who: portfolio managers, trustees, managers of collective assets, fund management companies and securities firms.
  • Core topics: licensing requirement, organisation and fit and proper conduct, ongoing supervision.

Frequently asked questions

Who needs a licence under FinIA?

The financial institutions listed in Art. 2 FinIA need a licence: portfolio managers and trustees (Art. 17), managers of collective assets (Art. 24), fund management companies and securities firms. FINMA grants the licence before the commercial activity starts. Peak Compliance guides portfolio managers and managers of collective assets through this procedure.

What does a supervisory organisation do?

Portfolio managers and trustees are supervised on an ongoing basis by a supervisory organisation under FINMASA (Art. 61 FinIA); FINMA authorises and supervises the supervisory organisations. FINMA currently lists AOOS, OSIF, OSFINcontrol and SO-FIT. Managers of collective assets are supervised directly by FINMA.

What does FINMA review in the licensing procedure?

FINMA reviews, among other things, a registered office in Switzerland, an appropriate organisation including compliance and risk management, sufficient financial guarantees and the fit and proper status and qualifications of the persons responsible. The details follow from FinIA, FinIO and FinIO-FINMA. Peak Compliance prepares the application and the organisation in a structured way.

What applies after the licence is granted?

The institution meets the licensing conditions on an ongoing basis and notifies planned changes to the facts underlying the licence in advance to the supervisory organisation; depending on the change, FINMA approves it. Peak Compliance takes over the compliance and risk management function from day one.

Sources

Isabelle Ledergerber, Managing Partner, Co-Founder at Peak Compliance
Responsible
Managing Partner, Co-Founder · LinkedIn profile

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