Stablecoins and the Swiss franc

The early franc stablecoins

Stablecoins are tokens whose value is linked to a currency or another asset and which are intended to serve as a means of payment or settlement on a blockchain. The first franc stablecoin came from Crypto Valley. At the end of October 2018 Swiss Crypto Tokens, a company majority-owned by Bitcoin Suisse, issued the CryptoFranc, or XCHF, whose tokens were linked one to one to the franc and legally structured as bonds. The first tranche of ten million units sold out before the issue date. The chief executive Armin Schmid argued that volatility had become an obstacle to the wider use of crypto-assets. A director of Bitcoin Suisse, Luzius Meisser, pointed out that Swiss law then allowed the creation of such instruments without a specific licence, whereas platforms trading them would need a securities licence.¹

In March 2020 Sygnum launched its Digital Swiss Franc, or DCHF, which was backed by corresponding franc balances that the bank held at the Swiss National Bank. The token was intended in the first place for the settlement of trades in tokenised securities on the planned SDX platform and for the automated distribution of dividends on digital shares. Sygnum’s co-founder Mathias Imbach called trustworthy stablecoins of central importance for the development of the new asset economy.² Neither of these early franc stablecoins reached a significant volume. The global stablecoin market came to be dominated by dollar tokens, above all Tether’s USDT and Circle’s USDC, while the franc remained a marginal currency on public blockchains.

FINMA’s guidance of July 2024

Because Swiss law contained no specific rules for stablecoins, FINMA had to assess them under existing banking, collective investment and anti-money laundering law. A stablecoin with a claim to repayment at a fixed value generally amounts to the acceptance of deposits from the public, which requires a banking licence. Many issuers avoided this consequence by relying on an exception in the Banking Ordinance for deposits secured by a default guarantee from a bank. On 26 July 2024 FINMA published Guidance 06/2024, in which it noted that the widespread use of default guarantees created risks for stablecoin holders and for the guaranteeing banks. It set out minimum requirements for such guarantees and emphasised the increased risks in the areas of money laundering, terrorist financing and the circumvention of sanctions.³

The requirements are demanding. Each holder must have an individual claim against the guaranteeing Swiss bank, the guarantee must cover at least the sum of all deposits from the public including interest, the covered deposits may not exceed the guaranteed amount, and holders must be able to access the guarantee quickly and without complication. On the side of anti-money laundering law, FINMA requires issuers to identify all holders of the stablecoin as contracting parties, to establish their beneficial owners and to monitor transactions. It regards even a temporary holding as a permanent business relationship. The industry criticised the identification requirements as a serious obstacle to the use of Swiss stablecoins on public blockchains, where tokens circulate freely between holders unknown to the issuer.⁴

The reform of the Financial Institutions Act

The legislator has taken up the issue. On 22 October 2025 the Federal Council opened a consultation on an amendment to the Financial Institutions Act, which ran until 6 February 2026. The draft introduces two new licence categories. The payment instrument institution replaces the existing fintech licence and may issue a specific form of stablecoin. Client funds are to be segregated from the institution’s estate in bankruptcy, the ceiling of 100 million francs on accepted deposits is to be removed and stricter anti-money laundering rules are to apply to the issue of stablecoins. The crypto institution is intended for the provision of various crypto services, with licensing requirements modelled on those for securities firms but less strict, and with safeguards against conflicts of interest. The Federal Council explained that the reform was meant to improve the framework conditions for market development and the attractiveness of the Swiss financial centre while addressing risks to financial stability, integrity and the protection of investors and consumers.⁵

The consultation revealed broad agreement on the objectives but considerable disagreement on the details. Industry participants warned against over-regulation, lengthy licensing procedures and a “Swiss finish” that would place Swiss firms at a disadvantage compared with competitors in the European Union under the Markets in Crypto-Assets Regulation. Authorities and some political participants gave priority to integrity, reputation and the fight against money laundering.⁶ As at September 2026 the dispatch to Parliament was still awaited. The reform and its relationship to the fintech licence and the DLT Act are discussed in more detail in chapter J.I.

The banks’ sandbox of 2026

In anticipation of the new law, the Swiss banks have begun to test a franc stablecoin together. On 8 April 2026 UBS, PostFinance, Sygnum, Raiffeisen, the Zürcher Kantonalbank, the Banque Cantonale Vaudoise and Swiss Stablecoin AG announced a joint sandbox for a franc stablecoin. Swiss Stablecoin AG provides the technical basis for the issue. The tests are to run throughout 2026 in a controlled live environment, with a limited group of participants and caps on transactions. The initiative remains open to other banks, companies and institutions.⁷ The composition of the group is remarkable. It brings together the only global bank, the largest cantonal bank, the postal bank, the cooperative banking group and a crypto bank in a single project. That constellation suggests that the established banks regard a franc stablecoin as a matter of the whole financial centre and want to prevent the franc market on blockchains from being shaped by non-bank issuers or by foreign dollar tokens.

The Swiss Bankers Association had prepared the ground with an expert report of April 2025. It took a deliberately neutral position, neither recommending nor rejecting the introduction of stablecoins. It saw opportunities in lower transaction costs and automated processes, in particular for cross-border payments, and risks in disintermediation, a possible reduction of bank lending, the effectiveness of monetary policy and financial stability. A trusted franc stablecoin issued by Swiss banks could contribute to the development of the digital financial centre, provided that high standards of value stability, legal structure and supervision were met.⁸

The position of the Swiss National Bank

The Swiss National Bank has been consistent in its approach to digital money. It does not intend to issue a digital franc for the general public. It sees no clear advantages for the public in a retail central bank digital currency, since Switzerland has a modern payment system and sufficient electronic means of payment. It also warns that such a currency could destabilise the financial system by draining deposits from banks. It remains committed to cash, which a large majority of the population wants to keep. At the same time it considers that digital central bank money for financial institutions could make the financial system more efficient and secure, which is the purpose of Project Helvetia.⁹

On stablecoins the SNB has been sceptical without being hostile. In April 2023 Thomas Moser, then an alternate member of the Governing Board, explained that stablecoins and wholesale central bank money could coexist in principle. He added that stablecoins would need to offer added value compared with central bank money, so that customers would not hold only the bankruptcy-proof central bank instrument.¹⁰ In September 2025 the SNB chairman Martin Schlegel was reported as saying that Switzerland did not need a stablecoin.¹¹ Schlegel had earlier rejected proposals to hold bitcoin in the SNB’s reserves, citing extreme volatility, insufficient liquidity and the vulnerability of software-based systems. He described crypto-assets, with a total market value of about two trillion francs at the time, as a niche phenomenon compared with the global financial system.¹² A popular initiative launched in December 2024 to oblige the SNB to hold bitcoin alongside gold failed in May 2026, when its promoters announced that they had collected only about half of the 100,000 signatures required.¹³

The SNB’s preferences are clear from this record. It favours settlement in central bank money for wholesale transactions and accepts that private stablecoins and tokenised deposits may develop for other uses, subject to regulation that protects monetary sovereignty and financial stability. For the Zurich banks this means that a franc stablecoin will be tolerated if it is fully backed, supervised and bankruptcy-remote, but that it will not receive privileged access to central bank money.

Notes

swissinfo.ch, “Crypto bond catapults Swiss franc onto blockchain”, 31 October 2018, https://www.swissinfo.ch/eng/business/stable-coin_crypto-bond-catapults-swiss-franc-onto-blockchain/44512880. ↩
swissinfo.ch, “Sygnum bank creates digital version of Swiss franc for trading”, 23 March 2020, https://www.swissinfo.ch/eng/business/stablecoin-launched_sygnum-bank-creates-digital-version-of-swiss-franc-for-trading/45636334. ↩
FINMA, “FINMA publishes guidance on stablecoins”, media release, 26 July 2024, https://www.finma.ch/en/news/2024/07/20240726-m-am-06-24-stablecoins/. ↩
Grant Thornton Switzerland, “FINMA specifies practice on stablecoins”, https://www.grantthornton.ch/en/insights/stablecoins/. ↩
State Secretariat for International Finance (SIF), “Federal Council moves forward with stablecoins and crypto: consultation launched”, 22 October 2025, https://www.sif.admin.ch/en/newnsb/x4TMWQ1SWofNoFx7XyHhY. ↩
VE Law, “FINIG Vernehmlassung abgeschlossen – Was ist mit Krypto Instituten?”, 2026, https://www.velaw.ch/finig-vernehmlassung/. ↩
UBS, “UBS, PostFinance, Sygnum, Raiffeisen, Zürcher Kantonalbank, BCV and Swiss Stablecoin AG launch joint CHF stablecoin sandbox”, media release, 8 April 2026, https://www.ubs.com/global/en/media/display-page-ndp/en-20260408-stablecoin.html. ↩
Swiss Bankers Association, “A stablecoin can be a valuable addition – under clear conditions”, 30 April 2025, https://www.swissbanking.ch/en/media-politics/news/a-stablecoin-can-be-a-valuable-addition-under-clear-conditions. ↩
Swiss National Bank, “Will the Swiss franc soon only exist digitally?”, SNB explained, https://www.snb.ch/en/snb-explained/cbdc, consulted September 2026. ↩
finews.com, “Digital Central Bank Money: The SNB Breaks New Ground”, 28 April 2023, https://www.finews.com/news/english-news/57080-snb-digital-central-bank-money-thomas-moser-wholesale-retail-stablecoin. ↩
PANews, “Swiss National Bank President: Switzerland does not need stablecoins”, 10 September 2025, https://panews.io/articles/af61092d-2d0f-452f-835c-70248f0d1f4e. The report cites Jinshi financial news and gives no venue or reasoning. ↩
swissinfo.ch, “Swiss central bank chief rejects holding bitcoin in reserves”, 1 March 2025, https://www.swissinfo.ch/eng/archive-banking-fintech/swiss-central-bank-chief-rejects-holding-bitcoin-in-reserves/88947727. ↩
Blocktrainer, “Zu wenige Unterschriften: Kampagne zur Schweizer Bitcoin-Reserve vor dem Aus”, 9 May 2026, https://www.blocktrainer.de/blog/kampagne-zur-schweizer-bitcoin-reserve-vor-dem-aus. ↩

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.

English

Contact

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.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

Get in touch →