FINMA licence for managers of collective assets (fund managers) under Art. 24 FinIA

Firms managing collective investment schemes or pension fund assets in Switzerland above the legal thresholds need a FINMA licence as a manager of collective assets under Art. 24 FinIA, filed with and supervised by FINMA. Peak Compliance clarifies the right licence, prepares organisation and documents and guides the process through to the decision.

Responsible: Isabelle Ledergerber Last reviewed: 5 November 2026

FINMA licence in 4–6 months

With Peak Compliance, your application is plannable from the outset. The timeline shows the phases from needs analysis to licence; the individual steps follow further below in The application process in seven steps.

Timeline to the licence: typically 4–6 months
  1. 1
    Weeks 1–2
    Needs analysis and proposal
    Business model, fund volumes, key people, timeline; proposal.
  2. 2
    Weeks 2–8
    Organisation and documents
    Directives, organisation chart, business plan, ICS, risk management, fit-and-proper files.
  3. 3
    Months 2–3
    Application on the EHP
    Entry on FINMA's platform with all enclosures.
  4. 4
    Months 3–6
    Review by FINMA
    FINMA queries, additions, decision.
  5. ✓
    After 4–6 months
    Licence granted – start under supervision
    Commercial register, direct FINMA supervision, compliance and risk management from day one.
Goal: licence after 4–6 months

Indicative values from completed procedures, from needs analysis to licence. The authority decides on the outcome and its timing.

Portfolio manager or manager of collective assets?

Schematic view of pooled assets under the licence for managers of collective assets

Every project starts with the right licence category. Under Art. 24 para. 2 FinIA, the following are treated as portfolio managers:

  • managers of collective investment schemes for qualified investors with assets, including leverage, of no more than CHF 100 million, or
  • no more than CHF 500 million if the portfolio uses no leverage and investors have no redemption right for five years after their first investment;
  • managers of pension assets of no more than CHF 100 million in total and, in the mandatory segment, no more than 20 per cent of any single pension fund.
FeaturePortfolio manager (Art. 17)Manager of collective assets (Art. 24)
LicenceFINMAFINMA
Applicationvia a supervisory organisationdirectly with FINMA
Ongoing supervisionsupervisory organisationFINMA
Legal formsole proprietorship, commercial company or cooperativecommercial company
Auditcycle of up to four years possible (Art. 62)generally annual (Art. 63)
DetailsPortfolio manager licencethis page

Firms below the thresholds may voluntarily request this licence under Art. 24 para. 3 FinIA.

FINMA licence requirements for managers of collective assets

FINMA lists in particular the following conditions (FINMA page):

  • Legal form and organisation: commercial company with an organisation appropriate to its role, including corporate governance, risk management and effective internal controls (Art. 9 FinIA).
  • Fit and proper: proper business conduct by the firm and its senior persons (Art. 11 FinIA).
  • Capital: the required minimum capital and further collateral under FinIO.
  • Business scope: described precisely, in substance and geography, in the articles of association, partnership agreement or organisational regulations.
  • Activity: management of at least one collective investment scheme or the assets of at least one pension fund.
  • Tasks: portfolio management and risk management for the assets managed (Art. 26 FinIA).

Establishing a Swiss fund manager from abroad

International groups and fund initiators usually plan three things early:

  • Management in Switzerland: the firm is effectively managed from Switzerland, and its managers reside where they can actually exercise management (Art. 10 FinIA).
  • Swiss-resident representative: the firm can be represented by a person resident in Switzerland who sits on the management or the governance body (Art. 37 FinIO).
  • Branch or own company: a foreign manager that opens a Swiss branch or employs staff in Switzerland follows separate FINMA rules (Art. 52 and Art. 58 FinIA); this page covers a Swiss company with its own licence.

FINMA provides its application templates in English as well as in German, French and Italian. Peak Compliance works from Zurich and supports you on site or remotely.

Roles and scope

  • FINMA: grants the licence and supervises the manager of collective assets directly; no supervisory organisation is involved.
  • Audit firm: generally audits annually (Art. 63 FinIA).
  • Pension funds: remain responsible after delegating asset management and are supervised by the occupational pension supervisory authorities.
  • Peak Compliance: prepares, guides and, if you wish, takes over compliance and risk management. FINMA takes the decision.
  • Other licences: Liechtenstein on FMA licence; overview on FINMA and FMA licensing.

The application process in seven steps

  1. 1
    Needs assessment
    business model, products, investor base, asset volumes, delegations and timetable; this sets the licence category and the fixed price.
  2. 2
    Organisation
    executive management, board, portfolio management, risk management, internal control and compliance, including delegations to third parties (Art. 27 FinIA).
  3. 3
    Documents
    Peak Compliance provides and tailors the templates: articles of association or organisational regulations, directives, organisation chart, business plan, contracts and fit and proper documentation.
  4. 4
    EHP access
    registration on FINMA's survey and application platform; access via the FINMA portal after FINMA's review.
  5. 5
    Application
    completed in the EHP and filed directly with FINMA.
  6. 6
    Questions
    we support additional information and FINMA's questions until the decision.
  7. ✓
    Operation
    direct FINMA supervision starts, with a working compliance and risk management function in place.

After licensing: compliance and risk management from day one

Under direct FINMA supervision, documented processes, an effective internal control system and clear reporting to management and the board carry the day-to-day work. Peak Compliance provides these through compliance outsourcing and risk management outsourcing and supports you in audits up to the closing meeting with the audit firm. Background: FinIA explained. Further reading: IT risks for managers of collective assets in the audit and Supervisory review 2026.

What does the licence cost?

  • Peak Compliance fee: fixed price from CHF 15'000, set after the needs assessment, covering the entire support through to the decision.
  • Authority fees: FINMA's fee for the licensing decision and the annual supervisory levy, charged directly by FINMA.
  • Ongoing operation: compliance and risk management outsourcing as agreed, usually as an annual flat fee.

You receive an overview of all three items before the start, so the budget is clear from day one.

English versions of Swiss federal acts are translations for information; the German, French and Italian texts are binding.

Why Peak Compliance

  • Peak Compliance AG, founded in 2024 and based in Zurich, focuses on portfolio managers and managers of collective assets in Switzerland and Liechtenstein.
  • Experience with FINMA licensing processes and mandates with asset managers supervised by FINMA and the FMA.
  • Templates for articles of association, directives, organisation chart, business plan and contracts.
  • A fixed price for the process, followed by compliance and risk management from the same partner.

Clarify your licence category now: reach Peak Compliance by phone, contact form or online booking on our contact page.

At a glance

ItemDetails
Who it is forFirms managing collective investment schemes or pension fund assets on a commercial basis (Art. 24 para. 1 FinIA)
Licensing and supervisionFINMA, directly (Art. 61 para. 3 FinIA)
Application routeSurvey and application platform (EHP) → FINMA
Legal formCommercial company (Art. 25 FinIA)
SubstanceEffective management from Switzerland (Art. 10 FinIA)
ThresholdsBelow Art. 24 para. 2 FinIA, the portfolio manager licence applies
PriceFixed price from CHF 15'000, set after the needs assessment; FINMA fees charged separately

Frequently asked questions

Who needs a manager of collective assets licence?

Firms that manage the assets of collective investment schemes or of pension funds on a commercial basis need this FINMA licence (Art. 24 para. 1 FinIA). In English, such firms are often called fund managers or asset managers of collective investment schemes. Below the thresholds of Art. 24 para. 2 FinIA, the portfolio manager licence applies instead.

When is a fund manager treated as a portfolio manager?

A firm is treated as a portfolio manager if it manages collective investment schemes for qualified investors of no more than CHF 100 million in total, or no more than CHF 500 million if no leverage is used and investors have no redemption right for five years. For pension assets, the limits are CHF 100 million in total and no more than 20 per cent of any single pension fund in the mandatory segment. Peak Compliance reviews this in the needs assessment.

What does the licence cost with Peak Compliance?

Peak Compliance charges a fixed price from CHF 15'000, set after a short needs assessment. FINMA's fees are charged separately and directly by FINMA. You receive an overview of all costs before the start.

How long does the FINMA process take?

With Peak Compliance, typically 4–6 months from the needs analysis to the licence. The duration depends on how complete the documents are and on FINMA's questions; FINMA decides on the outcome and its timing.

What substance does FINMA expect in Switzerland?

A manager of collective assets with its registered office in Switzerland is a commercial company that is effectively managed from Switzerland (Art. 10 and 25 FinIA). Its managers reside where they can actually exercise management, and the firm can be represented by a person resident in Switzerland on its management or governance body (Art. 37 para. 2 FinIO).

Can a portfolio manager apply voluntarily for this licence?

Yes. Firms below the thresholds may request a licence as a manager of collective assets under the conditions of Art. 24 para. 3 FinIA. Peak Compliance discusses with you which licence fits your fund and distribution plans.

Sources

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

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