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MiCA, Switzerland and Singapore compared

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The three regimes answer the same questions with different instruments. The table sets out the main points at 30 June 2026.

QuestionMiCA (EU)SwitzerlandSingapore
Legal formRegulation, directly applicableAmendments to ten federal acts (DLT Act) plus FINMA practicePSA 2019, SFA 2001, FSMA 2022 plus MAS notices
Token categoriesART, EMT, other crypto-assets; securities excludedPayment, utility, asset (FINMA); securities under FinSA/FinMIADPT, e-money, capital markets product, limited-purpose DPT
Issuance of payment/utility tokenWhite paper, notification, liability; no approvalNo licence; FINMA classification request advisableNo licence unless capital markets product
Stablecoin issuerEMT: credit institution or EMI; ART: authorised issuer with reserveBank or fintech licence (deposit) or CISA; FINMA Guidance 06/2024SCS framework (reserve, par redemption, capital); implementation pending
Service-provider licenceCASP authorisation, Art. 59 ff.; 10 servicesSRO affiliation plus FINMA licence by activityPSA licence (SPI/MPI); CMS licence; DTSP licence
Minimum capitalEUR 50,000 / 125,000 / 150,000 or 25 % of fixed overheadsCHF 100,000 (AG); CHF 300,000 (fintech licence); CHF 1.5 million (securities firm)S$ 100,000 (SPI) / S$ 250,000 (MPI)
PassportingWithin EU/EEA by notificationNoneNone
Third-country accessReverse solicitation only (Art. 61)Cross-border into Switzerland permitted for many activities if no Swiss presenceFSMA Part 9 captures Singapore base serving abroad
Custody of client assetsSegregation, custody policy, liability (Arts. 70, 75)Art. 242a/242b DEBA; Art. 16 BankAStatutory trust, segregation, cold storage
Market abuseTitle VI applies to all crypto-assets admitted to tradingArts. 142 ff. FinMIA for securities onlySFA Part 12 for capital markets products; PSA conduct rules
TransparencyDAC8 from 1 January 2026CARF: AEOI Act in force 1 January 2026; data collection from 2027 at the earliest, first exchange 2028 (see Part C VI, Part G VII)CARF commitment; first exchanges 2027 or 2028 (see Part M VII)
End of transition1 July 2026DLT Act fully in force since 1 August 2021DTSP cut-off 30 June 2025

Three conclusions follow. First, MiCA is more prescriptive than Swiss law and about as prescriptive as Singapore law in conduct and custody. In stablecoin issuance it is more permissive than both, because an EMI licence is easier to obtain than a Swiss bank licence and because MAS's framework had not yet been legislated at the cut-off date. Second, MiCA's absence of any third-country route is a deliberate policy and will not change in the near term. Swiss and Singapore firms should plan on that basis. Third, MiCA's market-abuse title has no counterpart in Switzerland for non-security tokens, which means that a memecoin pump that is a criminal offence in Frankfurt may be no offence in Zug. Part E, Chapter X, discusses whether that gap will close.

Practice note

Before you decide on a Union entity, run three tests on your current book. Count the Union-resident clients and the revenue they produce. Check whether any of them can be shown, with documents, to have approached you at their own initiative without any Union-directed marketing. Price the Vaduz or Dublin subsidiary with real substance. If the Union revenue does not cover the subsidiary within two years, geo-block and revisit when it does. If it does, start the application in the Member State whose authority has already authorised a business like yours, because the second application of a kind is always faster than the first.

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.

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.