New Swiss regulatory framework 2020

Offering collective investment schemes in Switzerland

The Swiss Federal Financial Services Act (FinSA) and the Swiss Federal Financial Institutions Act (FinIA) entered into force on January 1st, 2020, introducing an entirely new framework of conduct rules for Swiss financial intermediaries.

The changes introduced by FinSA/FinIA involve client categories, fund promoters as well as authorization and representation requirements.

Through FinSA/FinIA, Switzerland envisages harmonizing its financial market regulations with MiFID II, in order to facilitate the cross-border activities of Swiss financial institutions and to simplify equivalence recognition.

The main changes are:

  • The introduction of a register of client advisors of domestic and foreign financial service providers;
  • The redefinition of Swiss investor categories;
  • different requirements for collective investment schemes registration;
  • different requirements for fund document translation and publication.

Which requirements apply to your activity depends on what client categories you are offering to.