At a glance

1. Switzerland's revised Anti-Money Laundering Act entered into force on 1 October 2026. It brings certain professional advisers into the AMLA framework and requires covered advisers to affiliate with a FINMA-recognised self-regulatory organisation. [1, 2]

2. The new perimeter does not cover every lawyer, fiduciary, accountant or corporate consultant. It applies when a person professionally participates for a third party in a financial transaction connected with specified legal acts, or professionally provides a domicile or registered-office address for more than six months. [2, 3]

3. Professional activity is automatically established when any statutory threshold is crossed, including more than CHF 50,000 annual gross revenue, more than 20 clients or covered legal acts, more than CHF 5 million of third-party assets at any time, or more than CHF 2 million annual transaction volume. Activity can still be professional on the general facts even below those thresholds. [3]

4. Advisers already conducting professional covered activity when the reform started have until 1 December 2026 to apply for SRO affiliation. A person who becomes professional later generally has two months to apply. [3, 7]

5. Covered advisers must identify clients and beneficial owners, establish the object and purpose of the engagement, keep records, apply risk-based enhanced checks, organise compliance and report suspicions to MROS where the statutory reporting duty applies. [2, 5]

6. The immediate project is a perimeter exercise: classify each service, measure the professional thresholds, identify exceptions, select an SRO that accepts advisers and assemble an application backed by workable AML procedures.

The 2026 reform creates a new compliance decision for Swiss fiduciaries, corporate service providers, lawyers, notaries, accountants, real-estate advisers and businesses that provide registered offices. The relevant question is no longer simply whether the firm handles client funds. Certain advisory participation in a financial transaction can now trigger AMLA even when the adviser does not receive or transmit the assets.

This article explains who enters the new adviser category, which thresholds matter, what the SRO deadline means and how to prepare an application without confusing adviser supervision with the existing financial-intermediary regime.

1. What changed on 1 October 2026?

The revised AMLA and the new Act on the Transparency of Legal Persons and the Identification of Beneficial Owners entered into force on 1 October 2026. The package creates a federal transparency register and introduces due-diligence obligations for certain higher-risk advisory activities. [1]

AMLA now expressly applies to advisers. Professional financial intermediaries under Article 2 paragraph 3 and advisers under Article 2 paragraphs 3bis and 3ter must affiliate with an SRO recognised by FINMA. The SRO supervises the affiliated person for AMLA compliance; FINMA recognises and supervises the SRO itself. [4]

SRO affiliation is therefore a real supervisory relationship. The SRO sets detailed rules approved by FINMA, reviews the application, monitors members, arranges periodic audits and can impose sanctions or exclude a member. It is inaccurate to describe membership as a Swiss government licence or prudential authorisation.

2. Which advisory services are covered?

Article 2 paragraph 3bis AMLA covers natural persons and legal entities that professionally participate for third parties in financial transactions, including arranging funds, in connection with specified legal acts. The Money Laundering Ordinance explains that participation includes advice that causally contributes to the legal act connected with the financial transaction. [2, 3]

A non-operational entity is broadly a legal person, company, institution, foundation, trust, fiduciary company or similar arrangement that is not established or maintained to operate or support the operating activity of a business or group. Domiciliation is wider in one respect: Article 2 paragraph 3ter is not limited to non-operational entities.

The service description alone is not decisive. “Corporate consulting”, “bookkeeping”, “legal support” or “registered office” can contain covered and non-covered mandates. Each service should be tested against the client's requested legal act, the related financial transaction and the adviser’s actual contribution.

3. When is advisory activity professional?

The Ordinance states that advice is professional when it is an independent economic activity directed towards permanent income. It is in any event professional when at least one quantitative threshold is met. The test applies whether the activity is the firm's main business or a secondary service. [3]

These thresholds are not a universal safe harbour. The qualitative definition of an independent, permanent income-generating activity still comes first. A firm below all four figures should document why the activity is or is not professional rather than treating the limits as permission to ignore AMLA.

The treatment of related persons is narrower: their activity is included in the professional assessment only where it produces more than CHF 50,000 gross revenue in the calendar year. The Ordinance defines the relevant family and related-person categories. [3]

4. What is the SRO application deadline?

A covered adviser that was already professionally active when the revised rules entered into force must submit its SRO affiliation application by 1 December 2026. During the transitional period and while the application is pending, the adviser can continue covered activity within existing business relationships, including new covered instructions from existing clients. It should not use the pending application as permission to accept covered work from new clients. [7]

If the activity becomes professional after 1 October 2026, the adviser must comply with the applicable duties immediately and generally apply to an SRO within two months of crossing into professional activity. If no timely application is made, or affiliation is refused, continued covered adviser activity is prohibited. [3]

Because the thresholds are measured over a calendar year, a firm needs a live monitoring mechanism. Revenue, clients, covered legal acts, third-party assets and transaction volume should be reviewed monthly rather than calculated for the first time after year-end.

5. Which exclusions and boundary cases matter?

The revised law contains exclusions, and the Ordinance narrows the category further. Intra-group services are not treated as adviser activity. A genuine auxiliary person can also sit outside the adviser definition where the adviser selects and controls that person, includes them in organisational measures and training, pays them rather than the end client, and documents the arrangement in writing. [2, 3]

Lawyers and notaries have a statutory exclusion for activity connected with judicial, criminal, administrative or arbitration proceedings, including representation, preparation, fact finding, litigation-risk analysis, prevention and enforcement of outcomes. This is not a blanket professional exemption for every corporate, property or fiduciary mandate.

Audit work by persons or entities authorised or supervised by the Federal Audit Oversight Authority is excluded in respect of that audit activity. The law also contains lower-risk exclusions for specified transactions, including certain family, matrimonial, inheritance and gift contexts. Each exclusion should be matched to the exact facts.

Borderline cases should be recorded in a perimeter register. The file should state the service, client, entity type, transaction, money flow, duration, professional threshold, exception relied on and reviewer. This creates evidence that the firm assessed the reform rather than simply overlooking it.

6. What duties apply to covered advisers?

The adviser obligations are tailored, but they are operational. Covered advisers must identify the client, establish the beneficial owner and keep the required documentation. They must identify the object and purpose of the requested transaction or service and clarify its background and purpose when higher risk justifies it. [2]

The scope of simplified and enhanced due diligence follows risk. SRO regulations define the detailed application for their adviser members. The organisation must therefore align its procedures with the selected SRO rather than treating the statute as a complete operating manual.

fedpol confirms that advisers are now among the persons required to report suspicious activity to MROS. Reports and attachments are submitted through goAML. Adviser registration routes are available for firms already affiliated, firms with a pending SRO application and firms that meet the professional test. [5, 6]

7. What should the SRO application contain?

Every SRO applies its own admission process and regulations. The file should nevertheless explain the same core proposition: who the applicant is, which covered services it provides, who controls it, why its people are fit for the role and how AMLA duties will operate in practice.

A robust adviser application file normally includes:

• corporate documents, commercial-register extract and ownership chart;
• identification, CVs and declarations for directors, owners and responsible personnel;
• a precise description of current and planned advisory services;
• sample engagement letters, terms and customer forms;
• a perimeter analysis mapping each service to Articles 2 paragraph 3bis or 3ter;
• the calculation of all four professional thresholds;
• client and beneficial-owner identification procedures;
• risk classification, enhanced clarification and documentation procedures;
• MROS escalation and goAML reporting procedures;
• organisation, training, conflicts, outsourcing and record-retention arrangements; and
• information requested under the selected SRO's forms and fee rules.

Vague descriptions create avoidable questions. If the company offers formation, domiciliation, accounting and director services, the application should show which entity types it accepts, which countries it serves, whether it arranges funding, how long it provides an address, and how it separates covered and non-covered engagements.

8. Adviser status versus financial-intermediary status

A business can act as an adviser, a financial intermediary or both. The distinction affects the duties applied to each activity. When the same activity qualifies as both financial intermediation and covered advice, the financial-intermediary provisions take priority for that activity. A person conducting both categories can elect, under the statutory mechanism, to subject all activities to the financial-intermediary rules. [2]

This matters for fiduciaries and crypto-facing corporate service providers. Incorporating an entity, arranging funding, controlling payment instructions, providing wallets and operating exchange flows can create several regulatory roles. The firm should not assume that new adviser membership resolves a separate financial-intermediary or prudential licensing requirement.

9. Why this matters for crypto and international structures

The reform can affect a firm even when it does not operate a crypto exchange. A Swiss provider that establishes a foreign foundation or company for a token project, manages a non-operational holding entity, arranges contributions into that entity or provides its registered office may enter the adviser perimeter.

Where the provider also controls wallets, exchanges assets, transmits value or administers customer funds, the analysis moves beyond adviser status. SRO affiliation under AMLA is not a substitute for a FINMA FinTech licence, banking licence, securities-firm authorisation or another permission triggered by the actual service.

The application and banking file should tell one consistent story. Entity charts, engagement letters, websites, client onboarding, invoices, wallet permissions and payment flows should all support the role described to the SRO.

10. Implementation plan before the 1 December deadline

The deadline is for submitting an application, not for receiving automatic membership. Admission fees may remain payable even if an application is rejected, and the applicant should budget membership, training and audit costs in addition to application preparation. [7, 8]

Swiss adviser SRO checklist

1. Confirm whether the firm participates in any legal act listed in Article 2 paragraph 3bis.
2. Identify every domicile or registered-office service expected to exceed six months.
3. Separate non-operational entities from genuine operating entities.
4. Document the financial transaction and the advice's causal contribution.
5. Check intra-group, auxiliary-person, audit, proceedings and other statutory exclusions.
6. Calculate all four professional thresholds and retain the evidence.
7. Separate adviser activity from financial intermediation and prudentially regulated services.
8. Select a FINMA-recognised SRO that accepts the relevant adviser category.
9. Prepare customer, beneficial-owner, purpose, risk and documentation controls.
10. Register for goAML and establish an internal MROS reporting route.
11. Submit the affiliation request by the applicable deadline.
12. Restrict new covered mandates correctly while the application remains pending.

Frequently asked questions

When did the new Swiss AMLA adviser rules begin?

The revised AMLA and associated rules entered into force on 1 October 2026. Covered advisers already professionally active at that date generally have until 1 December 2026 to submit an SRO application. [1, 7]

Does every Swiss consultant need SRO membership?

No. The law covers specified professional adviser activities. The analysis considers the listed legal act, related financial transaction, causal participation, professional test and exclusions.

Is company formation covered?

Formation of a non-operational entity seated in Switzerland can be covered. Formation of an entity seated abroad can also be covered. Formation of a genuine Swiss operating company is treated differently under the wording and still requires a factual perimeter analysis. [2]

Does providing a registered office trigger AMLA?

Professional provision of an address or premises as an entity's domicile or registered office for more than six months falls within the new adviser definition, subject to the professional test and applicable exclusions. [2, 3]

Are the four thresholds safe harbours?

No. Exceeding any threshold establishes professional activity, but staying below them does not automatically exclude a business that meets the general qualitative definition of independent activity aimed at permanent income.

Can an adviser continue while the SRO application is pending?

The transitional rules allow covered work within existing business relationships while the timely application is decided. The firm should control acceptance of covered work from new clients and follow the selected SRO's guidance. [3, 7]

Is SRO membership a FINMA licence?

No. The adviser is supervised by the affiliated SRO for AMLA compliance. FINMA recognises and supervises the SRO. Membership does not provide a prudential licence for banking, securities, custody or deposit-taking activity. [4]

Related DM Strategy guides

• Swiss SRO License Requirements in 2026, covering directors, AML responsibility, substance and application evidence.
• Swiss SRO Membership Cost and Process, comparing application, membership, training and audit costs.
• Swiss Crypto Licence Routes, comparing SRO membership with FinTech and banking licences.
• Swiss SRO Membership, outlining DM Strategy's setup and application support.

Key primary sources

Disclaimer

This article is for information only and is not legal, tax or regulatory advice. The result depends on the exact service, legal act, financial transaction, entity, client relationship, duration, professional thresholds and available exclusions. New supervisory practice may develop as SROs apply the revised law.

DM Strategy helps Swiss corporate, fiduciary, crypto and payment businesses classify their activities, select an SRO, prepare the affiliation file and implement the AML operating model. If the 1 December deadline or a new Swiss mandate may affect your business, book an introductory call with DM Strategy before accepting additional covered engagements.