Anyone in Switzerland who, on a professional basis, accepts, holds or transfers third-party funds often needs no FINMA licence but membership of a self-regulatory organisation. Internationally this is often called an “SRO licence”. That is imprecise and creates false expectations: SRO membership is not a licence for a business activity but submission to anti-money laundering supervision. This article explains who must join, how an application is prepared and what matters when choosing. It does not replace advice on individual cases.
Who must join
Art. 14 para. 1 of the Anti-Money Laundering Act requires financial intermediaries under Art. 2 para. 3 AMLA to join an SRO recognised by FINMA. These are persons and companies active on a professional basis in the so-called parabanking sector: payment services, lending and leasing, trading on behalf of others, safekeeping of securities, many crypto services and certain fiduciary activities. Since January 2020 there has been no choice between direct FINMA supervision and SRO membership; the system relies exclusively on SROs.
Banks, insurers, securities firms and fund management companies are supervised by FINMA, not an SRO. Since the Financial Institutions Act, independent portfolio managers and trustees need a FINMA licence and are supervised by a supervisory organisation. Since 1 October 2026, the revised act also covers certain advisers, for example in connection with real estate transactions or setting up legal entities. For them the application deadline expires in December 2026; the chosen SRO confirms the exact date and requirements.
The prior question: is the activity professional?
Not every occasional payment for third parties makes a company a financial intermediary. The Federal Council’s ordinance sets thresholds, among others for gross revenue, number of contracting parties, power of disposal over third-party assets and transaction volume. Borderline cases are common: a family office triggering payments for family members, a fiduciary keeping accounts for clients, a start-up processing payments between users. Anyone unsure should clarify the question in writing before the activity starts. Joining later does not cure the period without supervision.
Which SRO
FINMA maintains the binding list of recognised SROs and updates it continuously. How much it moves shows in a comparison: the version from early August 2026 named eleven recognised SROs, the version from the end of October 2026 ten. Anyone choosing an SRO should always check the current list on finma.ch rather than rely on third-party lists.
Broadly there are two groups. Cross-industry SROs such as VQF, PolyReg, ARIF and SO-FIT admit a wide range of financial intermediaries. Industry SROs serve specific professions, for example the SRO of the Swiss Bar Association and the Swiss Notaries Association for lawyers and notaries. Five questions matter: does the SRO accept your business model, in which language does it work, what does its regulation mean day to day, for example on forms and documentation, how is its audit model organised, and what are the costs for admission, annual fees and audits?
What an application typically contains
Details vary, but the structure is similar at most SROs. A complete application usually includes:
- company details with commercial register extract, articles and organisation chart
- a precise description of the activity and business model, including client segments, countries and products
- details of governing bodies and managers with evidence of good repute, such as criminal and debt enforcement register extracts
- the person responsible for anti-money laundering and their training
- internal directives on due diligence, aligned with the SRO’s regulation
- an AML risk assessment of the business
Many SROs also require evidence of basic training or an induction course. The most common cause of delay is not a missing document but an activity description that is too general and directives copied from a template that do not fit the business. Both can be avoided by writing the application from the business model outwards.
After admission
Admission marks the start of operations. The due diligence duties apply from the first business relationship: identification, establishing the beneficial owner, risk rating, special clarifications and documentation. The SRO has compliance audited regularly, by recognised audit firms or its own auditors. Training obligations, notification of changes in organisation or activity and the annual fee come on top. Exclusion from the SRO has serious consequences, because the activity may not continue without membership.
What the audit wants to see
Audits draw samples from client files. The question is not whether a control was performed but whether it is documented: where is the risk rating, where the reasoning, where the signed Form A or Form K, where the sanctions screening result? Files kept so that these questions can be answered per client in minutes pass with little effort; files assembled from mailboxes before the audit cost time and audit fees.
Four pitfalls
First, starting the activity before membership is confirmed. Second, a risk assessment written once and never updated although new client groups were added. Third, unclear boundaries between supervised and unsupervised activities, especially for newly covered advisers. Fourth, documentation tied to individuals and lost when staff change. A sequence with verifiable criteria is in our SRO membership checklist.
Where software helps
Nobody needs software for the application itself. For operations afterwards it often makes the difference between a smooth and a laborious audit. In FLIORE, our family office operating system, KYC onboarding, periodic reviews and their evidence run per mandate with a continuous audit trail, and beneficial owners are assessed under the rules of their own jurisdiction. How FLIORE prepares for an SRO audit is described in FLIORE for SRO audits. It does not replace legal assessment where in doubt. Key dates of the AMLA revision and related rules are in our regulatory deadlines overview.