Becoming an independent asset manager: the path to FINMA authorisation

You have looked after clients at a bank for years and are weighing the step into independence. We leave the legal detail of the Financial Institutions Act to the law firms. This is about the entrepreneurial route from a practitioner’s view.

Becoming an independent asset manager in Switzerland means building an authorisation-bound financial institution. Since 1 January 2020, independent asset managers have been subject to the Financial Institutions Act (FinIA) and require authorisation from FINMA. The path there runs through affiliation with a supervisory organisation and a formal authorisation application.

This article structures the steps for experienced relationship managers and bankers considering the move. It shows what you have to build yourself and where a partner noticeably reduces the effort.

Schedule a conversation: we accompany the path to independence.

The essentials at a glance

• Authorisation duty since 1.1.2020: Independent asset managers need a FINMA authorisation under FinIA (source: FINMA; SWA Swiss Auditors).
• Minimum capital: CHF 100,000, paid in cash and maintained at all times (source: Art. 22 FinIA).
• Own funds: at least one quarter of the fixed costs of the last annual financial statement, no more than CHF 10 million (source: Art. 23 FinIA).
• Management: generally two qualified persons, an exception for one person is possible (source: Art. 20 FinIA).
• Four supervisory organisations: After the merger into OSFINcontrol (end of 2025) these are AOOS, OSIF, SO-FIT and OSFINcontrol (source: FINMA list; finews, 2025).
• Sequence: First build the organisation including risk management, then affiliate with a supervisory organisation, then submit the application to FINMA via the EHP platform (source: Art. 7 para. 2 FinIA; Pestalozzi).
• Ongoing audit: The prudential audit is risk-based and not necessarily annual; where risk is low, the audit period can be extended to up to four years. Its costs are separate from the supervisory levy (source: FINMA, risk-based audit approach).
• Legal entitlement: Anyone who meets all requirements has a legal entitlement to be granted the authorisation (source: Art. 7 para. 1 FinIA).
• State of practice: By the end of February 2025, FINMA had authorised 1,532 of 1,864 applications; 1,699 of these arrived within the transition period running until 31 December 2022 (source: FINMA review, Feb 2025).

What authorisation does an independent asset manager need?

An independent asset manager has needed authorisation from FINMA under the Financial Institutions Act (FinIA) since 1 January 2020. A prior affiliation with a FINMA-authorised supervisory organisation, which handles ongoing supervision, is a precondition. Without authorisation, the commercial management of third-party assets is not permitted.

Before 2020, affiliation with a self-regulatory organisation under anti-money-laundering law was sufficient for most independent asset managers. FinIA changed this picture fundamentally. The activity is today a prudentially supervised financial service, comparable with other authorised financial institutions, albeit with a supervisory regime calibrated to size.

The distinction from investment advice matters. Anyone who manages assets themselves on the basis of a power of attorney falls under the authorisation duty. Anyone who only advises is subject to the conduct rules of the Financial Services Act (FinSA), but not necessarily to the FinIA authorisation duty for asset managers. Most bankers weighing the step into independence want to run mandates and therefore need the authorisation.

How do you become an independent asset manager?

The route to independence runs in clear stages. You first define the legal form and enter the company in the commercial register. You then build the organisation with capital, own funds, management and proportionate risk management. Only then do you affiliate with a supervisory organisation and submit the application to FINMA.

Step 1: Legal form and commercial register

FinIA permits the sole proprietorship, the commercial partnership and the cooperative; an entry in the commercial register is required (Art. 18 FinIA). In practice, most new institutions choose the public limited company or the limited liability company, because liability, capital and governance can be structured cleanly that way. Management must generally consist of at least two qualified persons (Art. 20 FinIA). An exception for a single person is possible if proper business operation is demonstrated. This is one of the first entrepreneurial decisions: who do you bring on board as a second key person?

Step 2: Capital, own funds and fitness

The minimum capital amounts to CHF 100,000 and must be paid in cash (Art. 22 FinIA). Added to this are own funds of at least one quarter of the fixed costs of the last annual financial statement, but no more than CHF 10 million (Art. 23 FinIA). The law also requires adequate collateral or professional indemnity insurance. The responsible persons must offer assurance of proper business conduct and enjoy a good reputation (Art. 11 FinIA). A professional qualification is also required, with appropriate training and sufficient professional experience. For experienced relationship managers, this hurdle in particular is usually manageable.

Step 3: Risk management and internal control system

Even before the move to the supervisory organisation, an appropriate risk management and effective internal control belong to the organisation (Art. 9 and 21 FinIA). This is precisely where proportionality helps: with no more than five full-time positions or an annual gross income below CHF 2 million and a business model without elevated risks, risk management need not be independent of management (Art. 26 para. 2 FinIO). For many new institutions, a manageable internal control system with a control matrix and a lean set of directives is therefore sufficient. Individual functions can be outsourced to a qualified person or an external provider.

Step 4: Affiliation with a supervisory organisation

Before the application goes to FINMA, affiliation with a supervisory organisation (SO) must be demonstrated (Art. 7 para. 2 FinIA). The SO handles ongoing supervision of the institution. Since the merger into OSFINcontrol at the end of 2025, four supervisory organisations are currently authorised by FINMA: AOOS, OSIF, SO-FIT and OSFINcontrol. You select the SO, submit the dossier and receive an affiliation confirmation after a successful review.

Step 5: Authorisation application to FINMA

The application itself runs via FINMA’s survey and application platform (EHP). You register, select the supervisory organisation, complete the application and submit it in full to FINMA once the affiliation confirmation has arrived. If the institution meets all requirements, there is a legal entitlement to be granted the authorisation (Art. 7 para. 1 FinIA). That provides planning certainty: this is not a discretionary decision, but a review of clearly defined requirements.

What does a FINMA authorisation as an asset manager cost?

A credible flat figure does not exist. Fixed is the minimum capital of CHF 100,000 paid in cash (Art. 22 FinIA), plus own funds of at least one quarter of fixed costs (Art. 23 FinIA). Added to this are fees from the supervisory organisation and FINMA, the effort of preparing the application and ongoing supervisory levies. This levy recently averaged around CHF 6,500 per asset manager and year, and in individual cases total supervision costs reach CHF 10,000 or more (source: VSV / finews, 2025).

Separate from this are the costs of the ongoing audit, which are not included in the supervisory levy. As a prudentially supervised institution, an asset manager is audited periodically; the rhythm is risk-based and not necessarily annual: where risk is low, the audit period extends to up to four years, with standardised reporting in the audit-free years (source: FINMA, risk-based audit approach). Whether the supervisory organisation audits the institution itself or engages a licensed audit firm determines the size of this recurring cost block. Added to this is the ordinary statutory audit under the Swiss Code of Obligations: a company limited by shares or a limited liability company is in principle subject to a limited audit, but may waive it with no more than ten full-time positions on annual average (opting-out, Art. 727a para. 2 CO).

Alongside the direct authorisation costs stands the build-up requirement. A standalone institution needs connectivity to one or more custodian banks, a portfolio management system, defined investment processes, a compliance function and documented risk management. This infrastructure causes fixed costs, regardless of how many mandates you look after. This is precisely where it is decided whether the step pays off, and precisely where the question of a partner arises.

How long does the path to independence take?

The review by the supervisory organisation takes several weeks to a few months depending on the complexity of the dossier. After the affiliation confirmation arrives, FINMA reviews the complete application, which based on experience to date can again take roughly one to three months. A complete and well-documented submission shortens the procedure noticeably.

Realistically, you should plan for several months from the first planning to the granted authorisation, often six to twelve months. This time is not lost. You use it to build organisation, processes and the connection to a partner, so that you are operational from day one with the authorisation. Those who work in parallel rather than sequentially gain months.

With the authorisation, the ongoing obligations begin. The supervisory organisation reviews the institution periodically; where risk is low, the review period can be extended to up to four years, with standardised reporting in the review-free years. Added to this are the ongoing supervision by the SO and compliance with the obligations under anti-money-laundering law.

Build it yourself or go with a partner?

The regulatory route is feasible, but it is only half the story. The real entrepreneurial question is: do you want to put your energy into building infrastructure, bank connections and compliance, or into your client relationships? Every hour that flows into running your own apparatus is missing from the mandates that are your actual capital.

An established firm such as Everon supports experienced relationship managers on this path. You bring your client relationships and your experience, we provide infrastructure, investment processes and operational support. Everon is a FINMA-regulated asset manager and Multi-Family Office based in Zurich. Its own portfolio management team has received several BILANZ awards. This way you do not have to reinvent the wheel, yet you keep the closeness to your clients.

Which route is right depends on your goals, your client base and your risk appetite. Both models have their merit. What matters is that you make the choice consciously and on the basis of reliable facts.

Frequently asked questions about independence as an asset manager

What authorisation does an independent asset manager need in Switzerland? Since 1 January 2020, every commercially active independent asset manager needs authorisation from FINMA under the Financial Institutions Act (FinIA). A prior affiliation with a FINMA-authorised supervisory organisation, which handles ongoing supervision, is a precondition. Without this authorisation, the activity is not permitted.

How do you become an independent asset manager? You choose a legal form and enter your firm in the commercial register. You then build the organisation: capital, own funds, management and a risk management and internal control system. Only then do you affiliate with a supervisory organisation and submit the application via FINMA’s EHP platform. With the authorisation you may manage assets commercially.

What does a FINMA authorisation as an asset manager cost? The law requires a minimum capital of CHF 100,000 paid in cash (Art. 22 FinIA) plus own funds of at least one quarter of fixed costs (Art. 23 FinIA). Added to this are fees from the supervisory organisation and FINMA and ongoing supervisory levies, which recently averaged around CHF 6,500 per year. Added to this are the costs of the periodic prudential audit, which is risk-based and not necessarily annual, and where applicable the ordinary statutory audit under the Swiss Code of Obligations. A credible flat figure for the entire setup does not exist.

How long does the authorisation procedure take? The review by the supervisory organisation takes several weeks to a few months depending on complexity. After the affiliation confirmation arrives, FINMA reviews the complete application, which based on experience to date can again take roughly one to three months. Careful preparation of the application shortens the procedure.

Do I need a partner like Everon for independence? It is not mandatory. Many independent asset managers, however, do not build infrastructure, custodian-bank connectivity and risk management alone, but work with an established firm. This leaves more time for the client relationship. Everon supports experienced relationship managers on this path. This does not constitute investment advice.

The path to independence is demanding, but clearly regulated. If you are a relationship manager or banker weighing the step, a sober look at effort, costs and the question of what you carry yourself and what you hand to a partner is worthwhile.

Schedule a conversation: talk to us about your path to independence.

As at June 2026. Sources: FINMA, the Financial Institutions Act (FinIA), Financial Institutions Ordinance (FinIO) and the Swiss Code of Obligations (CO), and specialist publications by Pestalozzi, BDO and SWA Swiss Auditors. This article serves general information and does not constitute legal, tax or investment advice.