Switzerland, the European Union and financial market access

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The relationship between Switzerland and the European Union frames the question of market access for the crypto industry. Switzerland and the Union concluded negotiations on a package of agreements in December 2024, which updates the existing bilateral agreements and adds new ones on electricity, health and food safety.¹ Since the package does not include an agreement on financial services, Swiss financial institutions, including crypto service providers, continue to depend on the equivalence decisions of the Union and on their own subsidiaries in member states.

The Union has not adopted an equivalence mechanism under MiCA. The only route for Swiss crypto providers is a subsidiary authorised in a member state or in an EEA state such as Liechtenstein, a route that many Zug companies have taken. The result is a pattern in which the Swiss parent company holds the technology, the management and often the client relationships outside the Union, while the European subsidiary carries out the regulated activities for European clients. The pattern resembles the one that Swiss banks adopted for their European business after the Union tightened its rules on third-country providers. It reinforces the character of Zug as a headquarters location, which Part C described for the economy of the canton as a whole.

Notes

Federal Department of Foreign Affairs, "Package Switzerland–EU (Bilaterals III)", europa.eda.admin.ch: substantive conclusion in December 2024, formal conclusion and initialling in May 2025, consultation until end of October 2025, signature on 2 March 2026, dispatch to Parliament adopted in March 2026; European Commission press release IP/26/505, ec.europa.eu. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

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Switzerland, the European Union and financial market access

Notes

Setting up or expanding in Switzerland?