How to Become a FINMA-Licensed Portfolio Manager in Switzerland

Switzerland Is Now a Fully Regulated Market for Portfolio Managers

Since the introduction of FinIA (Financial Institutions Act) and FinSA (Financial Services Act), Switzerland has shifted from a partially-regulated environment to a fully-regulated, internationally aligned regulatory framework.

All portfolio managers and trustees must now be authorised by FINMA and supervised by a supervisory organization (SO), such as:

• OSFIN
• SO-FIT
• AOOS
• OAD-FCT
• OSIF

This framework brings Switzerland in line with EU-style regulations while maintaining the strengths that make the jurisdiction attractive:

• Political stability
• Strong investor protections
• Global wealth hub
• High trust in Swiss regulation

This guide explains exactly how to become a FINMA-authorised portfolio manager, from initial requirements to post-license operational readiness.

1. Who Needs a FINMA Portfolio Manager License?

Under FinIA, you must be licensed if you manage assets on a discretionary or individual portfolio basis for clients on a professional basis.

This includes:

• Independent asset managers
• External asset managers (EAMs)
• Multi-family offices
• Wealth managers
• Investment managers for individuals
• Delegated portfolio managers
• Boutique asset management firms

Exemptions (very limited)

Only apply if:

• Managing funds of <20 clients
• No compensation
• No professional activity
  → These exemptions rarely apply to real businesses.

2. The Regulatory Framework: FinIA vs FinSA

Switzerland’s regulatory architecture is built on two complementary laws:

FinIA (Financial Institutions Act) — Supervision & Licensing

Regulates:

• Portfolio managers
• Trustees
• Managers of collective assets
• Fund management companies
• Securities firms

FinSA (Financial Services Act) — Client Protection Rules

Regulates:

• Client classification
• Suitability checks
• Appropriateness tests
• Disclosure obligations
• Documentation & reporting
• Conduct rules

A FINMA portfolio manager must comply with both.

3. Licensing Process to Become a FINMA Portfolio Manager

The authorization process has four main steps:

1. ‍Prepare application documents ‍
2. Submit to supervisory organization (SO) ‍
3. SO review & approval ‍
4. FINMA final authorization

Let’s break them down.

4. Step-by-Step FINMA Licensing Requirements

Step 1: Organizational Requirements

FINMA requires:

A. Proper Governance

• Board of directors
• Executive management
• Clear segregation of duties
• Minimum 2 qualified managers

B. Fit & Proper Criteria

• Adequate professional experience
• Clean disciplinary record
• Personal integrity
• Relevant qualifications

C. Adequate Risk Management & Compliance

These may be:

Internal functions or Outsourced (if properly documented)

D. Minimum Capital

FINMA requires:

• CHF 100,000 minimum capital
• Additional financial resources proportional to risk

Step 2: Application Documentation

The application dossier includes:

4.1 Organizational Manual (OM)

Explains:

• Business model
• Governance
• Processes
• Investment approach
• Delegation/outsourcing

4.2 Risk Management Framework

Including:

• Investment risks
• Operational risks
• Liquidity risks
• Market & counterparty risks
• Controls & limits

4.3 Compliance Manual

Covering:

• Conduct rules
• Conflicts of interest
• Suitability/appropriateness
• Best execution
• AML/CTF processes
• Reporting & disclosure

4.4 Client Classification Procedures

Retail vs. Professional vs. Institutional.

4.5 Financial Forecasts

3-year business plan.

4.6 Internal Control System (ICS)

4.7 Key Persons Documentation

CVs, background, qualifications.

4.8 Outsourcing Agreements

If compliance, risk, or IT is outsourced.

Step 3: Submission to Supervisory Organization (SO)

The chosen SO performs:

• Completeness check
• Detailed review
• Clarification requests
• Compliance assessment
• Fit & proper evaluation

Once satisfied, the SO forwards the application to FINMA.

Step 4: FINMA Final Approval

FINMA reviews:

• SO’s assessment
• Governance
• Capital adequacy
• Manuals & controls
• Organizational structure

Once approved, FINMA issues your portfolio manager license.

5. Post-License Obligations for Swiss Portfolio Managers

Once licensed, the firm must comply with ongoing obligations:

5.1 Conduct Rules (FinSA)

• Client segmentation
• Disclosure obligations
• Suitability/appropriateness checks
• Documentation & reporting

5.2 Risk Management

• Ongoing monitoring
• Breach reporting
• Limit frameworks
• Stress testing (if applicable)

5.3 Compliance & Internal Controls

• AML/CTF
• Conflicts of interest
• Best execution evidence
• Periodic reviews

5.4 Annual Audit & SO Oversight

• Annual regulatory audit
• Continuous supervision by SO

5.5 Reporting Obligations

• Financial statements
• Risk reports
• Operational reports
• Outsourcing oversight documentation

5.6 Recordkeeping

FINMA requires complete, organized, and easily retrievable data.

6. Technology Stack Required to Operate as a FINMA-Regulated Portfolio Manager

Switzerland’s regulatory expectations require a robust operational infrastructure.

Essential Systems Include:

• Digital onboarding & AML/KYC tools
• Client classification workflow (FinSA)
• Portfolio management system (PMS)
• Multi-custodian data aggregation
• Reconciliation engine
• Performance & risk analytics
• Compliance monitoring tools
• Document management & audit trail
• Client reporting system
• Fee & billing engine
• Cybersecurity & IT governance

Why this matters

FINMA and SOs routinely review:

• Risk monitoring software
• Portfolio exposure accuracy
• Suitability / appropriateness evidence
• Documentation workflows
• Audit trails
• Governance of IT systems

A spreadsheet-based approach is not acceptable for regulated firms.

7. Why Swiss Portfolio Managers Choose Reluna

Reluna provides an end-to-end operational suite that satisfies the functional and regulatory needs of Swiss portfolio managers under FinIA/FinSA.

Reluna includes:

• Digital client onboarding & AML/KYC
• FinSA client classification
• Suitability & appropriateness workflows
• Portfolio management & analytics
• Multi-custodian aggregation
• Full reconciliation engine
• Compliance monitoring & controls
• Document vault & audit trail
• Client reporting portal (white-labeled)
• Fee & billing engine
• ESG reporting (optional)
• Comprehensive audit logs for SO & FINMA

Key benefits:

• Reduces time to operational readiness
• Satisfies SO/FINMA documentation expectations
• Provides clean, reconciled portfolio data
• Ensures ongoing compliance with FinSA conduct rules
• Supports supervisory inspections
• Avoids multi-system fragmentation

Reluna gives Swiss portfolio managers an enterprise-grade infrastructure from day one.

8. Licensing Timeline (Typical)

• Preparation | 1–3 months
• Submission to SO | 1–2 months
• SO Review | 3–6 months
• FINMA Final Approval | 1–3 months
• Go-Live | ~6–12 months total

Timeline varies based on complexity and completeness of application.

9. Common Mistakes Swiss Applicants Should Avoid

• Incomplete organizational manual
• Weak risk management processes
• Missing suitability/appropriateness workflow
• No independent compliance function
• Insufficient IT governance documentation
• Poor custodian data integration
• Relying on spreadsheets for oversight
• Weak outsourcing agreements

10. Next Steps: Launch Your FINMA-Regulated Portfolio Management Firm

Becoming a FINMA-regulated portfolio manager requires:

• solid governance
• strong risk & compliance
• operational readiness
• robust IT systems
• clear client documentation
• reliable reporting infrastructure

Reluna helps Swiss firms launch quickly and operate confidently under SO and FINMA supervision.

Request a Reluna demo to see how we support Swiss portfolio managers through full operational readiness.