CVA's Response on the FINIA Revisions

FINIA Revision, An Aligned Industry Voice for Proportionate Crypto Regulation

The Crypto Valley Association has submitted its response to the State Secretariat for International Finance on the proposed revisions to the Financial Institutions Act (FINIA). The submission was developed in close coordination with the Swiss Blockchain Federation and reflects extensive, joint industry expertise.

Download CVA's response letter from the attachment section below

CVA fully supports and endorses the SBF consultation response and highlights several aspects of particular relevance for its members, especially start ups and growth stage companies. Our shared objective is clear, risk based, technology neutral regulation that strengthens Switzerland’s competitiveness while avoiding unnecessary barriers to innovation.

Key points emphasized by CVA, in line with the SBF position:

♦ Proportionate, risk based regulation for crypto institutions, with custody as the primary prudential trigger and tiered supervision

♦Clear and practical stablecoin rules that avoid unintended restrictions on other payment tokens and respect established banking law concepts

♦Consistent token definitions and regulatory perimeter clarity to reduce legal uncertainty across Swiss financial market laws

♦Modernised AML requirements adapted to digital realities, including pragmatic approaches to digital onboarding and self custody wallets

♦Preservation of the SRO regime and licensing cascade as a cornerstone of Switzerland’s successful fintech and crypto framework

The FINIA proposal provides a solid foundation. With targeted refinements, as outlined jointly by SBF and CVA, it can ensure that digital assets, tokenisation, and DLT continue to scale responsibly in Switzerland.

We strongly encourage CVA members and industry participants to submit their own feedback to SIF and to reference or align with the CVA and SBF positions where appropriate. The consultation deadline is 6 February, so there is still time to contribute. A broad and consistent industry response is essential to ensure that practical experience from the market is fully reflected in the final regulatory framework.

Many thanks to Dr. Katharina Lasota Heller, Maxim Kon, Reto Luthiger, Dominik Hofmann,  and Biba Homsy for their work on drafting CVA’s response, as well as the experts from the Swiss Blockchain Federation.

Download CVA's response letter from the attachment section below