Launching an AMC in Switzerland: A Step-by-Step Guide
Launching an Actively Managed Certificate turns an investment strategy into a tradable certificate that can be subscribed via an ISIN. We walk through the path from the idea to the issuer to subscription, including the regulatory requirements.
A convincing investment strategy is one thing, turning it into a product investors can actually subscribe to is another. For wealth managers and financial intermediaries, an Actively Managed Certificate (AMC) is the pragmatic way to bridge that gap: without the effort of launching your own fund, but with a tradable certificate that can be represented via an ISIN. This article walks through how launching an AMC works in Switzerland and which regulatory requirements apply.
Launching an AMC means securitising a defined investment strategy as a structured product through a supervised issuer. Legally, this creates a debt instrument: investors hold a claim against the issuer, not a share in a separate pool of assets. The underlying asset is managed discretionarily according to the defined strategy throughout the term.
The essentials at a glance
- An issuer is mandatory: In Switzerland, an AMC may only be issued by a supervised institution, typically a bank (such as UBS or Goldman Sachs).
- The AMC advisor contributes the strategy: The wealth manager develops the strategy and oversees the underlying asset on an ongoing basis, while issuance sits with the issuer.
- Legal framework: An AMC falls under FinSA and FinIA, but is not a collective investment scheme under CISA. FINMA Circular 2025/2 (in force since 1 January 2025) is also relevant.
- Documentation depends on the target market: A public offering to private clients requires a prospectus and a key information document (KID); a private placement to professional investors does not.
- Timeline: With Everon, typically around three weeks until the certificate is ready for subscription.
Read more: Actively Managed Certificates (AMCs): Explanation and insights
What steps does launching an AMC involve?
Launching an AMC typically follows five steps: defining the investment strategy, selecting a supervised issuer, establishing the AMC advisor’s role, preparing the product documentation, and opening subscription. Ongoing management of the underlying asset then begins. Each step has its own technical and regulatory requirements.
It starts with the investment strategy: underlying assets, investment universe, target market, and rebalancing rules are defined. Next comes the choice of issuer, whose creditworthiness directly determines the issuer risk. Once the strategy and issuer are settled, the roles between issuer, AMC advisor, and any other service providers are clearly separated, the documentation is prepared, and an ISIN is requested. Subscription then makes the certificate tradable.
What role does the issuer play?
The issuer is the legal and regulatory backbone of the launch. Only a supervised institution, typically a bank, may issue an AMC in Switzerland on a legally certain basis. Issuers such as UBS or Goldman Sachs have the necessary licence and infrastructure. The issuer implements the strategy synthetically and bears legal responsibility for the certificate.
This structure is the source of the central risk. Because the AMC is a claim against the issuer, repayment depends on the issuer’s solvency. Issuer quality is therefore not a side consideration but a core criterion of the launch. A COSI pledge collateralisation can reduce issuer risk; its conditions and scope follow the recommendations of the Swiss Structured Products Association (SSPA).
What role does an AMC advisor like Everon take on?
The AMC advisor brings investment expertise to the launch. In this role, Everon develops the investment strategy and takes on ongoing portfolio management: within the defined strategy, the advisor adjusts the composition of the underlying asset and rebalances it. Issuance and legal responsibility remain with the issuer. This separation of functions is deliberate.
The clear separation between issuer, advisor, and any other service providers minimises conflicts of interest and creates traceable responsibilities. Since June 2026, FINMA Guidance 03/2026 on product risks in individual portfolio management has placed additional focus on how conflicts of interest are handled when products are used, in particular in-house AMCs: it calls for transparency about the product universe considered, objective selection criteria, and disclosure of unavoidable conflicts. For the financial intermediary, working with an AMC advisor means being able to implement a strategy without having to build the regulatory infrastructure of an issuer themselves.
What regulatory requirements apply when launching an AMC?
An AMC is a structured product and falls under FinSA and FinIA, not under CISA. This distinction follows the principle of “form over substance”; in borderline cases, a prior legal assessment or clarification with FINMA is advisable. The scope of documentation depends on the target market.
For a public offering to private clients, a prospectus and a key information document (KID) must be prepared, and the product may only be distributed by, or with the guarantee of, a supervised institution. For a private placement to professional or institutional investors only, the prospectus and KID requirements do not apply. Also relevant is FINMA Circular 2025/2, “Rules of conduct under FinSA/FinSO” (in force since 1 January 2025): it explicitly treats AMCs as separate financial instruments where the wealth manager shapes the underlying assets to a non-negligible extent, and requires corresponding information and conflict-of-interest disclosures. This does not constitute legal advice and does not replace a case-by-case review.
How long does it take to launch an AMC?
A tailored AMC can typically be set up with Everon within roughly three weeks. This makes it possible to turn an investment idea into a tradable instrument comparatively quickly. The actual duration depends on the complexity of the strategy, the chosen issuer, and the scope of documentation.
A private placement to professional investors is usually faster to implement than a public offering to private clients, since the prospectus and KID requirements do not apply. In both cases, the timeline remains manageable, especially compared with launching a fund of your own.
Frequently asked questions about launching an AMC
Who is allowed to launch an AMC in Switzerland?
Only a supervised institution, typically a bank, may issue an AMC. The wealth manager or financial intermediary contributes the investment strategy and, as AMC advisor, provides ongoing oversight of the underlying asset, while the legal issuance of the certificate sits with the issuer. This does not constitute investment advice.
How long does it take to launch an AMC?
A tailored AMC can typically be set up with Everon within roughly three weeks. The actual duration depends on the complexity of the strategy, the chosen issuer, and the scope of documentation, in particular whether the product targets professional investors only or also private investors.
What documentation does an AMC require?
For a public offering to private clients, FinSA requires a prospectus and a key information document (KID). For a private placement to professional or institutional investors only, the prospectus and KID requirements do not apply. In both cases, the certificate receives an ISIN and is made tradable through the issuer.
What risk does an AMC carry structurally?
An AMC is legally a debt instrument, meaning a claim against the issuer, not a share in a separate pool of fund assets. If the issuer defaults, investors face a partial to total loss, regardless of how the underlying asset performed. A COSI pledge collateralisation can reduce this issuer risk. This does not constitute investment advice.
Are you a financial intermediary looking to launch an AMC? Talk to us.
This article is for general information purposes only and does not constitute investment advice or an offer to buy or sell financial instruments. Everon AG is a wealth manager licensed by FINMA under FinIA. Past performance is not a reliable indicator of future returns.
