Driver 3: crypto-assets and Digital Assets and tokenised markets

Law ahead of the market

Part J has described how Switzerland built one of the most complete legal frameworks for crypto-assets and Digital Assets in the world. The DLT Act of 2020 introduced ledger-based securities and the segregation of crypto-assets in bankruptcy. FINMA’s token classification of 2018 and its guidance on stablecoins applied existing law in a technology-neutral way. The regulated crypto banks, the exchange-traded products listed on SIX and the digital bonds issued on SIX Digital Exchange and BX Digital gave the market institutional depth. On 22 October 2025 the Federal Council opened a consultation on a reform of the Financial Institutions Act that would create licences for issuers of stablecoins and for crypto institutions, with the aim of increasing Switzerland’s attractiveness for technology-driven business models.¹

Three elements of this landscape can be treated as predetermined for 2035. The legal infrastructure will remain in place and will probably be extended by the stablecoin and crypto institution legislation. The Swiss National Bank will continue to experiment with wholesale central bank money on regulated platforms. Its Project Helvetia will run until at least June 2028 and allows nine banks, including UBS, Raiffeisen and several cantonal banks, to settle transactions in wholesale central bank digital currency on the SIX Digital Asset Platform. The number of participants is unlimited for institutions that meet the SNB’s criteria.² Finally, the international exchange of information on crypto-assets under the OECD’s Crypto-Asset Reporting Framework, discussed in Chapter J.I, will make the tax transparency of crypto holdings comparable to that of bank accounts.

Open questions: the franc stablecoin and the platform race

The uncertainties lie in the market. On 8 April 2026 seven institutions, namely UBS, PostFinance, Sygnum, Raiffeisen, the Zürcher Kantonalbank, the Banque Cantonale Vaudoise and Swiss Stablecoin AG, launched a sandbox to test applications of a Swiss franc stablecoin throughout 2026. Their stated aim was to support a Swiss ecosystem for digital money and to gain practical experience. Observers described the initiative as the most institutionally significant attempt so far to create a regulated franc stablecoin with broad use in Switzerland.³ The SNB’s assessment is sober. In its 2026 report on financial stability it found that stablecoins currently pose minimal risks to financial stability in Switzerland.⁴

Whether a franc stablecoin becomes a widely used means of payment by 2035 depends on factors outside Swiss control. Dollar stablecoins benefit from the network effects of the world’s reserve currency and from American legislation that has given them a legal basis. European rules under the Markets in Crypto-Assets Regulation apply to euro-denominated tokens.⁵ A franc token may remain a niche product for settlement between Swiss institutions, or it may become the preferred instrument for tokenised Swiss securities and cross-border payments in a currency valued for its stability. The same uncertainty applies to tokenised markets more broadly. Zurich has the law, the central bank money and the platforms, yet it has not yet attracted volumes comparable to those of the conventional markets. The competitive question for 2035 is whether issuers, asset managers and custodians choose Swiss platforms for tokenised bonds, funds and private assets, or whether the business consolidates on platforms in the European Union, the United States, Singapore or the Gulf.

For the scenarios, this driver has a special character. It is the one field in which Switzerland can gain ground through its own legislation, since the legal and institutional preconditions are largely domestic. In a world of restricted access to the European market, tokenised infrastructure could offer a channel through which Swiss institutions reach international clients on the strength of technology and legal certainty. In a world of European integration, it could become one of Zurich’s specialisms within a larger market.

Notes

State Secretariat for International Finance, Tätigkeitsbericht 2025 (cited above), section on innovation. See also Chapter J.I on the content of the consultation draft. ↩
Swiss National Bank, “Questions and answers on Helvetia”, https://www.snb.ch/en/services-events/digital-services/faq-overview/qas_helvetia. ↩
Payment Expert, “Swiss banking giants launch CHF stablecoin sandbox”, 10 April 2026, https://paymentexpert.com/2026/04/10/swiss-chf-stablecoin-sandbox/. ↩
Swiss National Bank, Financial Stability Report 2026, landing page (cited above). ↩
The White House, “Fact Sheet: President Donald J. Trump Signs GENIUS Act into Law”, 18 July 2025, https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-president-donald-j-trump-signs-genius-act-into-law/, on the federal regulatory framework for payment stablecoins. ESMA, “Markets in Crypto-Assets Regulation (MiCA)”, https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica: Titles III and IV of Regulation (EU) 2023/1114 on asset-referenced tokens and e-money tokens have applied since June 2024, the remaining provisions since December 2024. ↩

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 September 2025.

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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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Driver 3: crypto-assets and Digital Assets and tokenised markets

Law ahead of the market

Open questions: the franc stablecoin and the platform race

Notes

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