Asset management

Institutions that manage collective assets, keep assets for collective investment schemes, represent foreign funds in Switzerland or manage occupational pension assets on a commercial basis generally need SFMA authorisation. Swiss collective investment schemes and certain foreign fund offerings also require approval of the relevant documents.

Institutions

The asset management perimeter includes fund management companies, managers of collective assets, custodians, representatives of foreign collective investment schemes and other institutions defined by the financial institutions and collective investment schemes legislation. The exact licence depends on the role performed and the assets under management.

Institutional authorisation is separate from product approval. A provider may need permission because it manages assets or acts as a custodian, while a fund or investment scheme may need approval because it is established or offered in Switzerland. Applicants should analyse both dimensions before launching a structure or marketing documents.

Authorisation requirements

Applicants must demonstrate adequate capital, fit and proper management, a suitable organisation, clear decision-making processes, risk management, compliance, proper custody arrangements and reliable auditability. SFMA also examines group structures, outsourcing, delegation and conflicts of interest.

The review places particular weight on investment decision processes, valuation, liquidity management, risk measurement, delegation of portfolio management, independence of control functions and the ability to treat investors fairly. Where portfolio management or administration is delegated, the applicant remains responsible for selection, instruction and monitoring of the delegate.

Managers of occupational pension assets must show that they can meet the standards expected for professionally managed pension assets. This includes appropriate expertise, risk controls, documentation of investment restrictions and transparent reporting to the pension institution.

Products

Swiss collective investment schemes require approval of fund documents before launch. Foreign collective investment schemes offered in Switzerland to non-qualified investors require approval or authorisation of the relevant documents and arrangements. Limited qualified investor funds follow a separate regime and are exempt from the ordinary approval and authorisation requirement.

The product analysis depends on the legal form and investor group. Contractual funds, investment companies, limited partnerships for collective investment and foreign schemes can involve different documents and parties. Marketing to non-qualified investors is subject to stricter safeguards than distribution restricted to qualified investors.

Requirements for approval

Product review focuses on investor protection, disclosure, investment policy, risk spreading, fees, custody, valuation and the responsibilities of the fund management company, custodian and other parties. The documents must be consistent with the law and with the intended investor group.

Offering documents should describe the investment policy, permitted techniques, leverage, risks, costs, redemption terms and valuation method in a way that is clear for the target investors. SFMA may ask for adjustments where documents are incomplete, inconsistent or do not adequately reflect the intended product.

Changes and cessation

Authorised asset management institutions must notify or obtain approval for material changes. This includes changes to organisation, ownership, key personnel, business model or product documents. If an institution ceases regulated activity, it must wind down in an orderly and legally compliant manner.

Changes to fund documents, service providers, delegation arrangements, investment policy or investor rights may require prior approval before they take effect. Institutions should therefore maintain a change process that identifies regulatory triggers early and keeps investors informed where required.

Submitting applications

Applications should be complete and tailored to the activity concerned. Early preparation of governance documents, risk policies, outsourcing contracts and product documentation helps the review proceed efficiently. Applicants should also be ready to explain operational workflows, system controls and the practical responsibilities of each party involved in the investment structure.

Scope of institutions and products

The asset management section covers both institutions and investment products. Institution pages include fund management companies, asset managers of collective assets, custodian banks, representatives of foreign collective investment schemes and legal forms such as SICAVs, SICAFs and limited partnerships for collective investment. Product pages cover Swiss fund contracts, foreign collective investment schemes and related approval routes.

This distinction matters because an operator can require authorisation for the role it performs while the product itself requires approval of documents. For example, a fund management company, custodian bank and collective investment scheme can each trigger separate legal questions even though they belong to the same overall investment arrangement.

EHP submission route

Applications, reports and data transmissions are handled through the electronic survey and application platform. Applicants that do not yet have access can use the self-registration route to request a licence and access. Once access is granted, the FINMA portal is used to transmit application material and follow-up information.

The application should be structured so the authority can understand the proposed activity without reconstructing it from scattered exhibits. Governance, risk management, delegation, valuation, custody, investor disclosure, conflicts of interest and outsourcing should be documented in a consistent way across the business plan, internal rules and contracts.

Changes after approval

Changes in ownership, responsible persons, organisation, delegated functions, products, fund documents or investor rights can require prior approval or notification. Institutions should maintain a change-control process that identifies regulatory triggers before implementation, especially where changes affect investors or the safeguarding of assets.

If activity is discontinued, the institution must plan an orderly cessation. This can include transferring mandates, amending fund documents, communicating with investors and ensuring records remain available for supervisory or audit purposes.