Swiss Federal Council stablecoin consultation of 22 October 2025
What the draft permits, what it permits only under conditions, and which issuance model each stablecoin category has to be built on.
Category status
- Allowed
- 3
- Allowed with conditions
- 3
- Not permitted
- 1
Consultation opened 22 October 2025. Reading of the draft — not legal advice.
What the draft regulates
The consultation introduces a dedicated Swiss regime for fiat-referenced payment tokens. Six pillars determine whether a given stablecoin design can be issued from Switzerland.
A dedicated authorisation for stablecoin issuers, sitting between the fintech licence and the full banking licence. The current bank-guarantee workaround under FINMA Guidance 06/2024 is intended to be replaced.
Full backing in high-quality liquid assets, legally segregated from the issuer's own balance sheet, with bankruptcy remoteness and regular independent attestation.
An enforceable claim to redeem at par in the reference currency, within a defined period and without disproportionate fees.
Payment stablecoins may not pay interest. Yield-bearing constructions are pushed into collective-investment or securities law instead.
Identification of holders at issuance and redemption, with transfer-monitoring expectations for the issuer and its distribution partners.
Offering into Switzerland is tied to equivalent home-country supervision and, where relevant, a Swiss point of contact.
Stablecoin categories mapped to issuance models
Each category in the Atlas corresponds to one or more concrete issuance models. The status shows how the 22 October 2025 draft treats the category; the requirement column explains what has to be true for the model to work in Switzerland.
What the draft requires
Dedicated stablecoin licence (or bank licence), segregated reserve, par redemption right, audited monthly attestation, AML/KYC on issuance and redemption.
Matching issuance model
What the draft requires
Full banking licence, esisuisse depositor protection up to CHF 100k, standard capital and liquidity requirements — no separate stablecoin authorisation needed.
Matching issuance model
What the draft requires
The joint entity must hold the licence itself; each participating bank's exposure must be ring-fenced and governance/liability allocation disclosed.
Matching issuance model
What the draft requires
Issuer of record retains reserve management, redemption obligation and AML duties; the brand partner may not be presented as issuer, and outsourcing rules (FINMA Circ. 2018/3) apply.
Matching issuance model
What the draft requires
Each issuer must hold and evidence its own segregated cover. Commingled or pooled reserve pools across issuers are incompatible with the draft's segregation rule.
Matching issuance model
What the draft requires
CISA-based fund structure or structured-note issuance with a prospectus, a licensed fund management company / securities firm and distribution rules — outside the stablecoin regime.
Matching issuance model
What the draft requires
May not be publicly issued as a payment stablecoin from Switzerland; no reserve construction under the draft satisfies the par-redemption and HQLA requirements.
Matching issuance model
Where to go next
Informational summary of a consultation draft dated 22 October 2025. The final ordinance may differ; this page is not legal advice.