Two federal acts govern asset management for third parties in Switzerland: the Federal Act on Financial Institutions (Financial Institutions Act, FinIA; in French LEFin, SR 954.1) and the Federal Act on Financial Services (Financial Services Act, FinSA; in French LSFin, SR 950.1). Both entered into force on 1 January 2020. The first sets the conditions under which an asset manager or a trustee may operate; the second governs how that firm must behave towards its clients. This page summarises both and points, for each item, to the article of the official text. It describes the framework and does not assess any provider.
The articles cited were checked against the texts published on fedlex.admin.ch (consolidated version of 1 January 2020). The texts may have been amended since: only the version currently in force on fedlex is authoritative.
When did the FinIA and FinSA enter into force?
The FinIA only enters into force together with the FinSA (art. 75, para. 3, FinIA). The Federal Council set that date at 1 January 2020 (note under art. 96 of the FinSA).
The transitional rules are in art. 74 FinIA:
- institutions already authorised under a financial market act (banks, for example) did not need a new licence and had to meet the FinIA requirements within one year, that is by the end of 2020 (para. 1);
- institutions that did not need a licence before 2020, such as most independent asset managers and trustees, had to notify FINMA within six months, then meet the requirements and file their application within three years of entry into force, that is by the end of 2022 (para. 2);
- they could continue to operate until the decision, provided they were affiliated with a self-regulatory organisation for anti-money laundering (para. 2);
- FINMA may extend these deadlines in certain cases (para. 4).
These deadlines have expired. Newcomers must meet the licensing conditions before they start operating.
Who needs a licence?
Art. 5 FinIA makes financial institutions subject to a licence from FINMA, the Swiss Financial Market Supervisory Authority. The two categories covered by this guide are defined in art. 17 FinIA:
- the asset manager (in French gestionnaire de fortune; in the Geneva market often called a GFI, for gérant de fortune indépendant): anyone who, on the basis of a mandate, professionally has power of disposal over client assets in the name and on behalf of clients (art. 17, para. 1);
- the trustee: anyone who professionally manages, or disposes of, segregated assets on the basis of a trust deed (art. 17, para. 2).
Art. 2, para. 2, FinIA excludes in particular persons who manage only the assets of people with whom they have economic or family ties (let. a), and certain lawyers and notaries acting within professional secrecy (let. c). The Financial Institutions Ordinance (FinIO, SR 954.11) clarifies these notions: family ties include in particular relatives and in-laws in the direct line, spouses and registered partners (art. 4 FinIO); economic ties concern entities of the same group (art. 3 FinIO).
A bank holding a licence under the Banking Act does not need a separate asset manager licence: art. 6 FinIA provides for a cascading licensing system.
What are the licensing conditions?
For asset managers and trustees, the FinIA and the FinIO set the following requirements.
| Requirement | Content | Legal basis |
|---|---|---|
| Legal form | Sole proprietorship, commercial company or cooperative; entry in the commercial register | art. 18 FinIA |
| Qualified managers | At least two qualified persons (one only if continuity is shown); five years of experience in asset management for third parties (or in the context of trusts) and at least 40 hours of training | art. 20 FinIA; art. 25 FinIO |
| Organisation | Adequate risk management and effective internal control (compliance) | art. 21 FinIA |
| Minimum capital | CHF 100,000, paid up in cash and maintained at all times | art. 22, para. 1, FinIA |
| Guarantees or insurance | Appropriate guarantees or professional indemnity insurance; FINMA sets the insurance rules | art. 22, paras. 2 and 3, FinIA; art. 31 FinIO |
| Own funds | At least one quarter of the fixed costs shown in the latest annual accounts, up to CHF 10 million | art. 23 FinIA |
| Supervisory organisation affiliation | Proof of being subject to a supervisory organisation from the time of the application | art. 7, para. 2, FinIA |
Art. 11 FinIA adds the guarantee of irreproachable business conduct. The amount of insurance cover is not set in the act: it follows from FINMA's rules, and we do not publish it.
How does two-tier supervision work?
Art. 61 FinIA sets out the principle: asset managers and trustees are subject to FINMA supervision, which involves a supervisory organisation (para. 1). Day-to-day supervision is carried out by supervisory organisations that hold a FINMA licence (para. 2). Managers of collective assets, fund management companies and securities firms are instead supervised directly by FINMA (para. 3).
In practice:
- FINMA grants the licence and withdraws it;
- the supervisory organisation (SO) monitors on an ongoing basis compliance with the conditions and the rules of conduct;
- the annual audit is entrusted to an audit firm, unless the SO carries it out itself; the SO may space audits out to once every four years depending on risk (art. 62 FinIA).
According to FINMA, the first supervisory organisations were licensed on 6 July 2020. An asset manager can change SO only at year-end, with a request filed by 15 November at the latest.
The licensed supervisory organisations
In the FINMA list we use, four supervisory organisations appear: AOOS, OSIF, SO-FIT and OSFINcontrol. The official list of licensed organisations is published by FINMA on its page on supervisory organisations.
This is the breakdown of the 549 Geneva institutions in our database (FINMA list and commercial register, registered office in Geneva, as of 17 October 2026; details on the Geneva data page):
| Supervision | Institutions |
|---|---|
| SO-FIT | 161 |
| AOOS | 149 |
| OSIF | 100 |
| OSFINcontrol | 10 |
| FINMA directly (banks, securities firms, managers of collective assets) | 126 |
These five rows add up to 546 institutions; three others in the database fall into none of them. Overall, 76.5 % of the 549 institutions are under an SO (as of 17 October 2026). Among independent asset managers, the share under an SO is 77.1 %; among trustees, it is 100 % (n = 61). Independent managers not shown under an SO are licensed directly by FINMA under another status. Private banks fall under FINMA's direct supervision.
What duties does the FinSA impose towards the client?
The FinSA applies to financial service providers, which include asset managers. Its rules of conduct read as a sequence of steps.
| Duty | Content | Article |
|---|---|---|
| Client segmentation | Private, professional or institutional clients; opting-out and opting-in | art. 4 and 5 FinSA |
| Information | Name and address, field of activity and supervisory regime, access to an ombudsman service, general risks of financial instruments | art. 8 FinSA |
| Timing and form of information | How the information is communicated to the client | art. 9 FinSA |
| Suitability check | For asset management: financial situation, investment objectives, knowledge and experience of the client | art. 10 and 12 FinSA |
| Appropriateness check | For investment advice on individual transactions | art. 11 FinSA |
| Exemption, impossibility of checking | Cases where the check is waived or cannot be carried out | art. 13 and 14 FinSA |
| Documentation | Agreed services, information gathered, services provided | art. 15 FinSA |
| Third-party remuneration | See below | art. 26 FinSA |
| Ombudsman service | Mandatory affiliation, information to the client | art. 74 and 77 to 79 FinSA |
The text of the FinSA distinguishes the appropriateness check, which concerns individual transactions (art. 11), from the suitability check, which takes the client's whole situation into account and applies to asset management (art. 12). The implementing ordinance is the Financial Services Ordinance (FinSO, SR 950.11).
What does the law say about retrocessions?
Remuneration received from third parties, commonly called retrocessions, is dealt with in art. 26 FinSA (and not in the FinIA). The provider may accept it if it has expressly informed the client beforehand and the client has waived it, or if the remuneration is passed on to the client in full (para. 1). The information covers the type and extent of the remuneration and comes before the service or the contract; if the amount is not known in advance, the provider communicates the calculation criteria and orders of magnitude and, on request, the amounts actually received (para. 2).
And the ombudsman service?
Art. 74 FinSA provides that disputes between provider and client should if possible be settled by an ombudsman service. Providers must join one at the latest when they start operating (art. 77) and inform their clients of this possibility (art. 79).
How do I find a firm in the FINMA list?
On its page on authorised institutions, individuals and products, FINMA publishes the registers that can be consulted. The list of authorised asset managers and trustees shows the supervisory organisation for each entry; it can be downloaded (XLSX or PDF) from the dedicated FINMA page. To find your way around it:
- search by company name or by enterprise identification number (UID number, of the form CHE-…);
- note the type of licence and the supervisory organisation;
- compare the registered office with the commercial register.
Our directory lists a firm only if it appears in a FINMA register; see the methodology. The guides on choosing a wealth manager and on fees complement this page.
What can be checked before signing?
The legal framework gives a list of concrete points to check before any mandate:
- The licence: is the firm in the FINMA list? Does the type of licence match the activity offered?
- The supervisory organisation: which one, and is the same name given in the list and in the contract?
- The custodian bank: do the assets stay in an account in the client's name, and what powers does the mandate give the manager?
- The fees: a written tariff, the basis of calculation and the custodian bank's charges, before signing (see the guide on fees).
- Retrocessions: does the manager receive any, and has the client received the information provided for in art. 26 FinSA?
- The ombudsman service: which one, and is its name in the documents handed over (art. 79 FinSA)?
- Client segmentation: in which client category has the provider placed the client (art. 4 FinSA)?
The directory remains a research tool: it does not assess the quality of a firm and does not replace legal or tax advice.