Stablecoins: the Swiss comparison
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Switzerland has no stablecoin statute. FINMA classifies stablecoins under existing law in its 2019 supplement to the ICO Guidelines and in Guidance 06/2024. A token redeemable at par against the issuer is a deposit under the Banking Act. A token backed by a managed pool is a collective investment. A token that is a payment instrument accepted by third parties is a means of payment under the AMLA (see Part E, Chapter VII). The Federal Council has considered a dedicated regime and had not legislated by 30 June 2026. The Swiss approach therefore produces bank-issued or bank-guaranteed stablecoins, such as those issued by Sygnum and AMINA, with the issuer either holding a licence or relying on a bank's default guarantee.
The Singapore approach produces non-bank issuers with a payment licence and a prescribed reserve. The two models reflect the two hubs' views of risk. Switzerland trusts the banking system and brings stablecoins into it. Singapore trusts a narrow, auditable reserve and keeps the issuer away from the banking system's balance sheet risk. For an issuer the Singapore model is cheaper to enter if the framework is enacted, because an MPI licence with S$ 1 million of capital is less demanding than a Swiss banking licence. The Swiss model gives the holder a deposit-insured or bank-guaranteed claim, which the Singapore model does not.
| Feature | Switzerland (FINMA practice) | Singapore (MAS framework) |
|---|---|---|
| Legal basis | Banking Act, CISA, AMLA as applied by FINMA guidance | PSA stablecoin issuance service (framework announced 2023; legislation pending at cutoff) |
| Eligible issuers | Banks, fintech licensees, issuers with bank default guarantee | MPIs; banks exempt from licence but subject to standards for the label |
| Reserve | Deposit treatment; bank balance sheet | ≥ 100 % in cash, cash equivalents and ≤ 3-month government paper of the pegged currency |
| Capital | Banking or fintech capital rules | Higher of S$ 1m or 50 % of annual opex; plus liquid assets |
| Redemption | Contractual; FINMA expects redemption at par | Within five business days at par, direct with issuer |
| Label | None | "MAS-regulated stablecoin" |
| Retail treatment | Depends on classification | Not a DPT; no consumer access restrictions; full value for accredited investor test |
| Multi-jurisdiction issuance | Not addressed | Not permitted at outset |
Practice note
If you intend to issue a stablecoin that Singapore residents will use, decide early whether you want the MAS-regulated label. The label requires issuance from Singapore, a reserve of the highest quality in the pegged currency, S$ 1 million or more of capital and a five-day redemption promise. It confines the issuer to issuance, redemption and custody. In exchange it takes the coin out of the DPT regime and lets retail customers hold it without restriction. If you do not want the label, the coin is a DPT in Singapore. Every licensee that lists it must apply the consumer measures, so the coin will compete at a disadvantage with labelled coins in Singapore distribution. The decision determines the group structure, the custodian relationships and the jurisdiction of issuance, so it should be made before the token contract is deployed.
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.