Circle welcomes Switzerland’s proposed stablecoin framework and calls for an equivalence-based pathway for regulated non-Swiss stablecoins, alongside targeted refinements to support interoperability, consumer protection, and financial stability.
Circle welcomes Switzerland’s proposed stablecoin framework and calls for an equivalence-based pathway for regulated non-Swiss stablecoins, alongside targeted refinements to support interoperability, consumer protection, and financial stability.
On February 6, 2026, Circle submitted its response to the Swiss Federal Council’s consultation on proposed amendments to the Financial Institutions Act (FINIG), which would introduce new licensing categories for payment institutions and crypto-institutions and establish a prudential framework for fiat-backed stablecoins (“wertstabile kryptobasierte Zahlungsmittel”).
Circle welcomes the initiative and supports the proposal’s core design choices, including full reserve backing, segregation of client assets, enforceable redemption rights, proportionate capital requirements, robust AML/CTF controls, and a technology-neutral perimeter that preserves non-custodial wallet software as unregulated technology. These elements provide a strong foundation for consumer protection, market integrity, and responsible innovation.
Ensuring Global Interoperability Through Equivalence
A central issue for Circle in the consultation is the treatment of non-Swiss stablecoins. As currently drafted, foreign-issued stablecoins - regardless of whether they are fully reserved and prudentially regulated in their home jurisdiction - would be treated in Switzerland in the same category as unbacked crypto-assets.
Circle believes this approach risks isolating Switzerland from global payment and settlement activity. Today, the global stablecoin market exceeds USD 300 billion, with regulated payment stablecoins increasingly used for cross-border payments, treasury operations, and on-chain settlement of tokenized assets. In the EU, MiCA recognizes e-money tokens as money-like instruments, while the U.S. GENIUS Act establishes a comparable framework.
To preserve Switzerland’s openness and competitiveness, Circle recommends introducing a clear equivalence-based regulatory pathway for prudentially regulated non-Swiss stablecoins. Under such a model, FINMA would recognize third-country regimes that are broadly comparable in objectives and supervisory outcomes, without requiring identical rules. Stablecoins issued under those regimes could then be treated in Switzerland as money-like instruments for accounting, prudential, and operational purposes. As a fallback, Circle suggests a narrowly tailored registration or recognition regime to avoid automatically classifying globally regulated stablecoins as unbacked crypto-assets.
Targeted Refinements to Support a Best-in-Class Framework
In addition to market access, Circle’s submission highlights several targeted refinements to strengthen the framework’s effectiveness and global alignment. These include recognition of foreign issuer disclosures - such as MiCA-compliant whitepapers; clarity around redemption rights and operational redemption models to ensure timely, orderly access to fiat; and a risk-based calibration of capital requirements that reflects operational and technological risks rather than token volume alone.
Circle also supports the proposal’s rejection of universal whitelisting in favor of risk-based AML/CTF controls aligned with Financial Action Task Force (FATF) standards, the inclusion of crypto-asset transfer services within the regulatory perimeter, and the use of transparent fees rather than automatic token supply reductions should negative interest rate environments re-emerge. Together, these measures enhance transparency, financial stability, and consumer trust while remaining consistent with global regulatory practice.
A Strategic Opportunity for Switzerland
By combining strong prudential safeguards with an equivalence-based approach to international stablecoins, Switzerland can reinforce its position as a trusted, innovative, and globally connected financial centre. Circle appreciates the opportunity to contribute to the consultation and looks forward to continued engagement with Swiss authorities as the framework moves toward implementation.
